d. waterquality-basedeffluent limitations (wqbels) · ntr) states that the salinity characteristics...

Fairfield-Suisun Sewer DistrictWastewater Treatment Plant

D. Water Quality-Based Effluent Limitations (WQBELs)

ORDER NO. R2-2009-0039NPDESNO. CA0038024

1. Scope and Authority

a. NPDES regulations at 40 CFR 122.44(d)(1 )(i) require pel1111ts to include WQBELs for.pollutants (including toxicity).thatareor maJ'be dischargedatJevels thatcause, have .reasonable potential to cause, or contribute to an excursion above any state water qualitystandard (Reasonable Potential). The process for detel111ining Reasonable Potential and,when necessary, calculating WQBELs is intended to (1) protect the designated beneficialuses of the receiving water specified in the Basin Plan, and (2) achieve applicable WaterQuality Objectives contained in the Califol11ia Toxics Rule (CTR), National Toxics Rule(NTR), and the Basin Plan.

b. NPDES regulations and the SIP provide the basis to establish Maximum Daily Effluei1tLimitations (MDELs).

(1) NPDES Regulations. NPDES regulations at 40 CFR 122.45(d) state, "Forcontinuous discharges all pennit effluent limitations, standards, and prohibitions,including those necessary to achieve water quality standards, shall unlessimpracticable be stated as maximum daily and average monthly discharge limitationsfor all discharges other than publicly owned treatni.ent works."

(2) SIP. SIP Section 1.4 requires that WQBELs be expressed as MDELs and averagemonthly effluent limitations (AMELs). Since the SIP requires MDELs, not averageweekly effluent limits, 'it is impracticable to impose average weekly effluent limits.MDELs are necessary to protect against acute water quality effects (e.g. forpreventing fish kills or acute mortality to aquatic organisms).

2. Applicable Beneficial Uses and Water Quality Criteria and Objectives

The Water Quality Criteria (WQC) and Water Quality Objectives (WQOs) applicable to thereceiving waters for this discharge are from the Basin Plan; the CTR, established by USEPAat 40 CFR 131.38; and the NTR, established by USEPA at 40 CFR 131.36. Some pollutantshave WQC or WQOs established by more than one of these three sources.

a.Basin Plan. The Basin Plan specifies numeric WQOs for 10 priority toxic pollutants, as. well as narrative WQOs for toxicity and bioaccumulation in order to protect beneficial

uses. The pollutants for which the Basin Plan specifies numeric objectives are arsellic,cadmium, chromium (VI), copper in freshwater, lead, mercury, nickel, silver, zinc, andcyanide. The narrative toxicity objective states in part, "all waters·shall be maintainedfree of toxic substances in concentrations that are lethal to or that produce otherdetrimental responses in aquatic organisms." The narrative bioaccumulation objectivestates in part, "controllable water quality factors shall not cause a detrimental increase inconcentrations oftoxic substances found in bottom sediments or aquatic life. Effects onaquatic organisms, wildlife, and human health will be, considered." Effluent limitationsand provisions in this Order are based on available infonnation to implement theseobjectives.

Attachment F - Fact Sheet F-19


ORDER NO, R2-2009-0039NPDES NO, CA0038024

b. CTR. The CTR specifies numeric aquatic life criteria for 23 toxic pollutants andnumeric human health criteria for 57 toxic pollutants. These criteria apply to all inlandsurface waters and enclosed bays and estuaries of the San Francisco Bay Region,although Basin Plan Tables 3-3 and 3-4 contain numeric objectives for certain toxicpollutants that supersede CTR criteria.

Human health criteria are further identified as "water and organisms" and "organismsonly." Because the receiving waters are not designated for the MUN beneficial use, theCTR criteria applicable to "organisms only" were used for the RPA.

c. NTR. The NTR establishes numeric aquatic life criteria for selenium and numerichuman health criteria for 33 organic pollutants for waters of San Francisco Bay upstreamto and including Suisun Bay and the Sacramento River-San Joaquin River Delta. TheseNTR criteria apply to Boynton Slough, Ledgewood Creek, and the duck ponds.

d. Basin Plan Receiving Water Salinity Policy. The Basin Plan (like the CTR and theNTR) states that the salinity characteristics (i.e., freshwater vs. saltwater) of the receivingwater shall be considered in determining the applicable WQOs. Freshwater objectivesapply to discharges to waters' with salinities equal to or less than one part per thousand(ppt) at least 95 percent of the time. Saltwater criteria shall apply to discharges to waterswith salinities equal to or greater than 10 ppt at least 95 percent of the time in a normalwater year. For discharges to water with salinities in between these two categories, ortidally influenced freshwaters that support estuarine ben'efi,cial uses, the criteria shall be .the lower of the salt or freshwater criteria (the latter calculated based on ambienthardness) for each substance. Receiving water salinity data collected at all receivingwater stations from March 2005 through July2008 indicate that 87% of the salinity datawere greater than 1 ppt but less than 10 ppt, which the Basin Plan defines as estuarine.

The Discl!arger has also performed plant community studies in the Boynton Slough andLedgewood Creek areas that indicate that the receiving waters are tidally influenced.Furthermore, all receiving waters (Boynton Slough, Ledgewood Creek, and the duckponds) are located within the Suisun Marsh, which is specifically identified by the BasinPlan as supporting the estuarine habitat beneficial use. The Reasonable PotentialAnalysis (RPA) and effluent limitations in this Order are therefore based on the morestringent of the fresh and salt water criteria.

e. Receiving Water Hardness. Ambient hardness values are used to calculate freshwaterWQOs that are hardness dependent. Ip.sufficient hardness data were available tocalculate an adjusted geometric mean from the data collected during the tern1 of theprevious pern1it after the data set was censored for hardness greater than 400 mg/L andsalinity greater than 1 ppt. The WQOs for this Order were therefore detennined using ahardness of 268 mg/L as CaC03, which was calculated in the previous permit as theadjusted geometric mean of 145 data points (after censoring the original data set,collected in Boynton Slough and adjacent sloughs to eliminate samples with hardnessvalues greater than 400 mg/L or salinity values greater than 1 ppt). Receiving waterhardness data were not available for Ledgewood Creek, and because the previous permitamendment (Order No. R2-2006-0045) indicated that receiving water conditions inLedgewood Creek are similar to those in Boynton Slough and adjacent sloughs, the samehardness assumption was made for all outfalls. '




f. Site-Specific Metals Translators. Because NPDES regulations at 40 CFR 122.45(c)require that effluent limitatiol1.s for metals be expressed as total recoverable metal, andapplicable WQOs for m'etals are typically expressed as dissolved metal, factors ortranslators must be used to convert metals concentrations from dissolved to totalrecoverable and vice versa. Ih the CTR, USEPA establishes default translators that areused inNPDESpennits; however, site-specific conditions, such as water temperature, .pH, suspended solids, and organic carbon, greatly affect the fonn of metal (dissolved,filterable, or otherwise) that is present in the water and therefore available to causetoxicity. In general, the dissolved fonn of the metals is more available and more toxic to'

aquatic life than the filterable fomls. Site-specific translators can be developed toaccount for site-specific conditions, thereby preventing .exceedingly stringent or underprotective WQOs.

Regional Water Board staff developed site-specific translators for hexavalent chroillium,copper, nickel, and zinc using data for dissolved and total metals collected by theDischarger in 2000 and 2001 during five sampling events. The following table shows thetranslators used for this Order. In determining the need for and calculating WQBELs forall other metals, default trahslators established by the USEPA in the CTR at 40 CFR131.38(b)(2), Table2, were used.

I t"fi Ta e - I e- ipeCI IC rans a ors

PollutantSite-Specific Translators

Acute Chronic

Chromium,VI 0.46 " 0.23

Copper 0.64 0.46

Nickel 0.9] 0.5] ,

Zinc 1.0 0.68

T bi F 9S't S

3. Determining the Need for WQBELs

NPDES regulations at 40 CFR 122.44(d)(l )(i) require pennits to include WQBELs for all.pollutants (non-priority and priority) "which the Director detennines are or may bedischarged at a level whicb will cause, have the reasonable potential to cause,or contribute toan excursion above any nalTative ornumeric criteria within a State water quality standard."Thus, assessing whether a pollutant has "Reasonable Potential" is the fundamental step indetennining whether a WQBEL is required. For non-priority pollutants, Regional WaterBoard staff used available monitoring data, the receiving water's beneficial uses, andprevious pennit limitations to detemline Reasonable Potential. For priority pollutants,Regional Water Board staff used the methods prescribed in SIP Section 1.3 to determine ifthe discharge from the Plant demonstrates Reasonable Potential as described below insections 3.a - 3.e.

a. Reasonable Potential Analysis (RPA)

Using the methods prescribed in SIP Section 1.3, Regional Water Board staff analyzedthe effluent data to detemline if the discharge from the Plant demonstrates ReasonablePotential. The RPA compares the effluent data with numeric and narrative WQOs in theBasin Plan and numeric WQC USEPA established in the NTR and CTR.



b. Reasonable Potential Methodology

ORDER NO. R2-2009-0039NPDES NO. CA0038024

Consistent with the methods and procedures prescribed in SIP Section 1.3,the RPAconsiders the maximum effluent concentration (MEC) for each pollutant based onexisting data, while accounting for a limited data set and effluent variability. There arethree triggers in determining .Reasonable Potential.

(1) The first trigger is activated if the MEC is greater than or equal to the lowestapplicable WQO (MEC ~. WQO), which has been adjusted, if appropriate, for pH,hardness, and translator data. If the MEC is greater than or equal to the adjustedWQO, then that pollutant has Reasonable Potential and a WQBEL is required.

(2) The second trigger is activated if the observed maximum ambient backgroundconcentration (B) is greater than the adjusted WQO(B > WQO) and the pollutant isdetected in any of the effluent samples (MEC > ND).

(3) The third trigger is activated if a review of other infoDnation detehnines that aWQBEL is required to protect beneficial uses, even though both MEC and B are lessthan the WQO. A limitation maybe required under certain circumstances to protectbeneficial uses. .

c. Effluent Data

The Regional Water Board's August 6, 200 I, letter titled Requirementfor Monitoring ofPollutants in E.fJluent and Receiving Water to Implement New Statewide Regulations andPolicy (August 6, 20.01, Letter- available online; see Standard Language and OtherReferences Available Online, below) to all permittees formally required the Discharger(pursuant to CWC Section 13267) to initiate or continue monitoring for the prioritypollutants using analytical methods that provide the .best detection limits reasonablyfeasible. Regional Water Board staff analyzed these effluent data and the nature of thePlant to detemline if the discharge has Reasonable Potential. The RPA was based on theeffluent monitoring data collected by the Discharger from November 2003 through July2008 for most inorganic pollutants, and from March 2005 through March 2008 for mostorganic pollutants. For bis(2-ethylllexyl)phthalate, due to the Bis(2-ethylhexyl)phthalateLaboratory Analysis Study, the values prior to the study were not used for the ReasonablePotential analysis. Therefore, the RPA used data from the study from September 2006 toAugust 2008.

d. Ambient Background Data

Ambient background values are used to deteDnine Reasonable Potential and to calculateeffluent limitations, when necessary. For the RPA, ambient background concentrationsare the observed maximum detected water column concentrations. The SIP states that forcalculating WQBELs, ambient background concentrations are either the observedmaximum ambient water column concentrations or, for WQOs intended to protect hunlanhealth from carcinogenic effects, the arithmetic mean of observed ambient waterconcentrations. The Regional Monitoring Program (RMP) station located in theSacramento River is a far-field background station that has been monitored for most of


Fairfield·Suisun Sewer DistrictWastewater Treatment Plant


the inorganic (CTR constituent numbers 1-15) and some of the organic (CTR constituentnumbers 16-126) toxic pollutants, and these data from the RMP were used as backgrounddata in perfomling the RPA for this discharge.

i;'.

The RMP has not analyzed all the constituents listed in the CTR. These data gaps areaddressed by the August 6, 2001, Letter. The August 6,2001, Letterfonnally requiresDischargers (pursuant to ewc Section 13267) to conduct ambient backgroundmonitoring and effluent monitoring for those constituents not currently monitored by theRMP, and to provide this technical information to the Regional Water Board.

On May 15, 2003, a group of several San Francisco Bay Region dischargers (lmown asthe Bay Area Clean WaterAgencies, or BACWA) submitted a collaborative receivingwater study, entitled San Francisco Bay Ambient Water Monitoring Interim Report(2003). This study includes monitoring results from sampling eveilts in 2002 and 2003for the remaining priority pollutants not monitored by the RMP. The RPA was conductedand the WQBELs were calculated using RMP data from 1996 through 2003 forinorganics and organics at the Sacramento River RMP station, and additional data fromBACWA's Ambient Water Monitoring: Final eTR Sampling Update (2004) for theSacramento River RMP station. The Discharger may use the receiving water studyprovided by BACWA to fulfill all requiremellts of the August 6,2001, Letter forreceiving water monitoring in this Order.

e. Reasonable Potential Determination

The MECs, most stringent applicable WQOs, and background concentrations used in theRPA are presented in Table F-IO, along with the RPA results (Yes or No) for eachpollutant analyzed. Reasonable Potential was not detel111ined for all pollutants, as thereare not applicable WQOs for all pollutants and monitoring data are not available forothers. Based on a review· of the effluent data collected during the previous pemnt te1111,the pollutants that exhibit Reasonable Potential are zinc, cyanide, chlorodibromomethane,dichlorobromomethane, and total ammonia by Trigger 1; dioxin-TEQ by Trigger 2; andcopper by Trigger 3.

Discharges of mercury are regulated by Regional Water Board Order No. R2-2007-0077,which became effective March 1,2008. Order'No. R2-2007-0077 is a Watershed Pemlitthat implements the SanFrancisco Bay Mercury TMDL and establishes wasteloadallocations for industrial and municipal wastewater discharges of this pollutant. Thedischarge of mercury from the Plant is.therefore regulated by means other than thisOrder. .

bl P t f I A I . ST bi F 10 Ra e - . easona e o en la nalYSlS ummary

MEC or Minimum DL GoverningMaximum Background

CTR# Priority Pollutants(.)(h) (I!g/L) WQO/WQC (Ilg/L)

or Minimum DL I<,)(h) RPA Results 'e)

(I!g/L) .

1 Antimonv 0.6 4300 0.34 No

2 Arsenic 1.2 36 3.7 No

3 Belyllium <0.041 No Criteria 0.126 No

4 Cadmimil 0.2 2.5 0.066 No

'Sa Chromium (m) 1.2 464 Not Available No

Attachment F ~ Fact Sheet F-23



MEC or Minimum DL GoYerningMaximum Background

CTR# Priority Pollutants("l(h) (J.lg/L) WQO/WQC (J.lg/L)

or IYIinimum DL I(.)(h) RPA Results (0)

(J.lg/L)

5b Chromium (VI) 2.6 35 Not Available No

6 Copper 9.2 13 9.9 Yes

7~ .. Lead 1.1 8.5 2.3. No

8 Mercurv (303d listed) --- --- --- ---9 Nickel (303d listed) (d) 8.2 16 (8.2) 22 (3.2) . No

10 Selenium (303d listed) 4 5 0.45 No

11 Silver 0.06 2.2 0.057 No

J2 Thallium 0.08 6.3 0.143 No

13 Zinc 46 90 J8 No

14 Cvanide 10 2.9 0.5 Yes

J5 Asbestos No Effluent Data. No Ctitelia Not Available No

J6 2,3.7,8-TCDD < 6.4E-08 1.4E-08 6.0E-09 No

Dioxin TEQ (303d listed) 3.02E-09 1.4E-08 4.8E-08 Yes

] 7 Acrolein i 780 < 0.5 No

J8 Acrylonitrile < 0.33 0.66 <0.02 No

J9 Benzene <0.03 7J <0.05 No

20 Bromoform 8.8 360 <0.5 No

2r Carbon.Tetrachloride 0.7 4.4 0.06 No

22 Chlorobenzene < 0.03 21000 <0.5 No

23 Chlorodibromomethane 44 34 . <0.05 Yes

24 ChIoroethane <0.03 No Criteria <0.5 Ud

25 2-Cilloroethvlvinvl ether <0.] No Ctiieria <0.5 Ud

26 Chlorofonn 72 No Criteria <0.5 Ud

27 Dichlorobromomethane 64 46 <0.05 Yes

28 J,J-Dichloroethane <0.04 No Criteria < 0.05 No

29 1,2-Dichloroethane <0.04 99 0.04 No

30 J,J-Dichloroethvlene <0.06 3.2 <0.5 No

3J 1,2-Dichloroorooane <0.03 , 39 <0.5 No

32 J3-DichlorooroovJene <0.03 1700 Not Available No

33 Ethylbenzene <0.04 29000 <0.5 No

34 Methvl Bromide <0.05 4000 , <0.5 No

35 Methvl Chloride 0.4 NO'Ctitetia <0.5 Ud

36 Methvlene Chloride 0.7 1600 <0.5 No

37 J,J,2,2-Tetrachloroethane <0.04 II < 0.05 No

38 Tetrachloroetlwlene 0.06 8.9 <0.05 No

39 Toluene 3.2 200000 < 0.3 No

40 1,2-Trans-Dichloroethvlene <0.05 140000 <0.5 No

4J J,I,J-Trichloroethane <0.03 No Criteria <0.5 ·No

42 J,J ,2~Trichloroethane < 0.05 42 < 0.05 No

43 Trichloroethylene <0.05 81 < 0.5 No

44 Vinyl Chloride 0.09 525 < 0.5 No

45 2-Chloroohenol <0.7 400 Not Available No

46,

2,4-Dichlorophenol <0.7 790 <1.3 No

47 2.4-DimethyJnhenol <0.8 2300 <1.3 No

48 2-Methyl- 4.6-DinitroiJhenol <0.6 765 < 1.2 No

49 2,4-Dinitroohenol <0.6 J4000 <0.7 No

50 2-Nitrophenol <0.6 No Critetia <1.3 Ud

51 4-Nitrophenol <0.6 No Criteria < 1.6 Ud

52 3-MethyJ4-ChJoroohenoJ <0.6 No Critetia <l.l Ud

53 Pentachloronhenol <0.6 7.9 <I No

54 Phenol <0.6 4600000 <1.3 No

55 204,6-Trichlorophenol <0.6 6.5 <1.3 No

56 Acenaohthene <0.03 2700 0.0019 No


Faitiield-Suisun Sewer DistrictWastewater Treatment Plant


MEC or Minimum DL GoverningMaximum Backgl'ound

CTR# Priority PollutantsC,)Ch) (Jlg/L) WQO/WQC (Jlg/L)

or Minimum DL I(,)(hl RPA Results C'I

(Jlg/L)

57 Acenaphthvlene <0.02 No Criteria 0.000492 Ud

58 Anthracene <0.02 110000 0.000389 No

59 Benzidine <I 0.00054 < 0.0003 No

60 Benzo(a)Anthracene <0.02 0.049-- - - - O.()(jj 1 --- ... No _ ...... 1--

61 Benzo(a)pyrene <0.02 0.049 0.0008215 No

62 Benzo(b)Fluoranthene <0.02 0.049 0.0019 No

63 Benzo(ghi)Pervlene <0.02 No Criteria 0.0012465 Ud

64 Benzo(k)Fluoranthene <0.02 0.049 0.000928 No

65 Bis(2-Chloroethoxy)Methane <0.7 No CriteJia <10 Ud

66 Bis(2-Chlorocthvl)Ethcr < 0.7 1.4 < 0.3 No

67 Bis(2-Chloroisopropvl)Ether < 0.6 170000 Not Available No

68 Bis(?-EthvlhexyI)Phthalate C') 1.6 5.9 0.69 No

69 4-Bromophenvl Phenvl Ether <0.8 No Criteria <0.23 Ud

70 Butvlbenzvl Phthalate 0.9 5200 <0.5 No

71 2-Chloronaphthalene <0.6 4300 <OJ No

72 4-Chlorophenyl Phenvl Ether <0.9 No Criteria <0.3 Ud

73 Chrvsene < 0.02 0.049 0.001067 No

74 Dibenzo(a,h)Anthracene <0.02 0.049 0.00067 No

75 1.2-Dichlorobenzene < 0.03 17000 < 0.3 No

76 1,3-Dich10robenzene <0.03 2600 <0.3 No

77 1,4-Dichlorobenzene 0.1 2600 <0.3 No

78 3.3 Dichlorobenzidine <0.6 0.077 < 0.0002 No

79 Diethvl Phthalate <0.6. 120000 Not Available No

80 Dimethv1 Phthalate <0.6 2900000 Not Available No

81 Di-n-Butvl Phthalatc <0.6 12000 1.72 No

82 2.4-Dinitrotoluene <0.6 9.1 <0.27 No

83 2.6-Diniu·otoluene <0.5 No Criteria <0.29 Ud

·84 Di-n-Octvl Phthalate <0.7 No Criteria Not Available Ud

85 1.2-Diohenvlhvdrazine < 0.6 0.54 0.0087 . No

86 Fluoranthene <0.02 370 0.0034255 No

87 Fluorene <0.02 14000 0.0024 No

88 Hexaeh101'0benzene <0.7 0.00077 0.000109 No

89 Hexachlorobutadiene <0.7 50 < 0.3 No

90 Hexachlorocyclooentadiene <0.8 17000 <0.3 No

91 Hexachloroethane <0.6 8.9 <0.2 No'

92 Indeno( I ,2,3-cd)Pvrene <0.02 0.049 0.001317 No

93 lsophorone <0.5 600 < 0.3 .No

94 Naphthalene < 0.02 No Criteria 0.00681 Ud

95 Nitrobenzene <0.7 .1900 <0.25 No

96 N-Niu'osodimethvlamine <0.6 8.1 <0.3 No

97 N-Ni\rosodi-n-Propvlamine' <0.6 1.4 < 0.0002 No

98 N-Nitrosodiphenylamine <0.6 16 <0.001 No

99 Phenanthrene < 0.02 No Criteria 0.003442 Ud

100 Pvrene < 0.02 11000 0.00358 No

101 1,2.4-Trichlorobenzene <0.8 No Criteria <0.3 No

102 Aldrin < 0.002 0.00014 0.00000404 No

103 Alpha-BHC < 0.002 0.013 0.0003468 No

104 Beta-BHC < 0.002 0.046 0.000118 No

105 Gamma-BHC < 0.002 0.063 0.0010032 No

106 Delta-BHC <0.002 No Ctiteria. 0.000038 . Ud

107 Chlordane (303d listed) ·<0.02 0.00059 0.0003 No

108 4.4'-DDT (303d listed) < 0.002 0.00059 0.000349 No

109 4,4'-DDE (linked to DDT) < 0.003 0.00059 0.00092 No



ORDER NO. R2-2009-0039NPDES NO. CAOO.38024

MEC or Minimum DL Governing Maximum BackgroundCTR# Priority Pollutants

(,,)(h) (J,Lg/L) WQO/WQC (J,Lg/L)or Minimum DL I<"l(h) RPA Results (,j

(J,Lg/L)

llO 4,4'-DDD <0.002 0.00084 0.000347 No

III Dieldrin (303d listed) < 0.002 0.00014 0.00038 No

112 Alpha-Endosulfan < 0.002 0.0087 0.0000571 No

113 beta-Endolsulfan <.0.002 0.0087 0.0000424 No

ll4 Endosulfan Sulfate < 0.002 240 0.000284 No

ll5 Endrin < 0.002 .0.0023 0.00015 No

ll6 Endrin Aldehvde < 0.002 . 0.81 Not Available No

117 Heptachlor < 0.003 0.00021 0.000011 No]]8 Heptachlor Epoxide < 0.002 0.00011 0.000097 No

119-i25 PCBs sum (303d listed) <0.02 0.00017 0.0007923 No

126 Toxaphene <0.15 0.0002 Not Available No

Tributvlin <0.00017 0.0074 0.00214 No

Total PAHs <0.02 15 0.0175332 No

Total Ammonia (moiL N) 2.] 2.05 0.6 Yes

Footnotes for Table F-l0:

(a) The Maximum Effluent Concentration (MEC) and maximum background concentration are the actual detected concentrationsunless preceded by a "<" sign, in which case the value shown is the minimum detection level (DL). '

(b) The MEeor maximum background concentnition is "Not Available" when there are no monitoring data for the·constituent.(c) RPA Results = Yes, ifMEC > WQOfWQC, B > WQOfWQC and MEC is detected, or Trigger 3;

= No, if MEC and Bare < WQOfWQC or all effluent data are undetected;= Undetennined (Ud), ifno criteria have been promulgated or there are insufficient data.

(d) . Dissolved nickel values are shown in parenthesis. Comparing dissolved nickel background data to the dissolved nickel WQOdoes not trigger RP. Since only total nickel was measured in the effluent, the translated nickel WQO was used for that part ofthe '~nalysis (similar to the other metals),

(e) Bis(2-ethylhexyl)phthalate background data with reporting limits exceeding the water quality objective were not used in theRPA because data from concurrently collected and analyzed samples with lower reporting limits were available. In addition,only effluent data collected using clean sampling techniques was used in the RPA.

(1) Constituents with limited data. In some cases, Reasonable Potential call1lot bedetermined bec~use effluent data are limited or ambient background concentrationsare not available. The Discharger will continue to monitor for these constituents in theeffluent using analytical methods that provide the best feasible detection limits. Whenadditional data become available, further RPA will be conducted to determinewhether to add numeric effluent limitations to this Order or to contjnue monitoring.

(2) Pollutants with No Reasonable Potential. WQBELs are not included in this Orderfor' constituents that do not demonstrate Reasonable Potential; however, monitoringfor these pollutants is still required. If concentrations of these constituents are foundto·have increased significantly, the Discharger is required to investigate the sources ofthe increases (see Provision VLC.2.a of this Order). Remedial measures are requiredif the increases pose a threat to water quality in the receiving water.

Order No. R2-2003-00n included WQBELs for cadmium and chromium; however,be~ause the RPA showed that discharges from the Plant no longer demonstrateReasonable Potential for these pollutants, this Order does not retain these effluentlimitations. This is consistent with State Water Board Order No. WQ 2001-16.



4. WQBEL Calculations.

a. Pollutants with Reasonable Potential


WQBELs were developed for the toxic pollutants that were detennined to havereasonable potential to cause or contributetQexceedances of WQOs. TheWQBELswerecalculated based on appropriate WQOs and the appropriate procedures specified in SIPSection 1:4. The WQOs used for each pollutant with Reasonable Potential are discussedin Section 4.d below.

b. Shallow/Deep Water Discharge

Discharges from the Plant to Boynton Slough, Ledgewood Creek, and the duck ponds areshallow water discharges. The outfall at Discharge Point 001 is submerged under mostconditions, except during extreme low tides, and the outfall at Discharge Point 005 is onthe shoreline and only possibly submerged during wet weather.

c. Dilution Credit

The shallow receiving waters support biologically selisitive and critical habitats.Therefore, no dilution credit (D=O) was used to calculate WQBELs for most pollutants,with the exception of cyanide, which is a non-persistent pollutant that readily degrades toa non-toxic state. Cyanide attenuates in receiving waters due to both degradation anddilution. Dilution credits for cyanide for specific shallow water discharges, including thatto Boynton Slough at E-OO 1, are established in the Basin Plan. The dilution creditaccounts for attenuation of cyanide in the receiving water. A dilution ratio of 4: 1 (0 = 3)has been applied in calculating effluent limitations for cyanide at E-OO 1; however, SIPrequirements for granting a mixing zone and dilution credits have not been met for theother outfalls (E-002, E-003, and E-005).

SIP Section 1.4.2.1 's requirements for granting dilution credits and mixing zones forincompletely mixed discharges were addressed by the StaffReport on Proposed Site-

.Specific Water Quality Objectivesfor Cyanidefor San Francisco Bay, prepared by the. Regional Water Board dated December 4,2006 (Cyanide SSO Staff Report). Flow

Science Inc., of Pasadena, CA, completed a mixing zone study for FSSD in 2004. Thisstudy modeled the dilution characteristics of the discharge from E-OOI to BoyntonSlough, and showed that irtlpacts from Fairfield-Suisun's discharge were insensitive towater-year conditions, and highly localized in Boynton Slough and the connecting reachof Suisun Slough (Cyanide SSO Staff Report, Appendix E, Page E-4).

SIP Section 1.4.2.2's mixing zone conditions are also addressed by the Cyanide SSOStaff Report, which finds:

(I) The mixing zone does not compromise the integrity of the receiving water. The areaof the mixing zone is 3.5 acres, versus the area of the receiving water, which is 35acres (Cyanide SSO Staff Report, Appendix D, Table I).

(2) The mixing zone does not cause acutely toxic conditions to aquatic life passingthrough the mixing zone. This finding is based on analysis of the sensitivity of


Fairfield-Sl.lisun Sewer DistlictWastewater TTeatment Plant

ORDER NO.R2-2009-0039NPDES NO. CA0038024

receptor ~pecies to cyanide compared with the measured levels of total cyanide alongthe discharge gradients of shallow water dischargers. These concentrations are lessthan the threshold acute toxicity levels and are not anticipated to increase (CyanideSSO Staff Report, Appendix J, Page J-5).

(3) Themixingzonedo~snotrestrict'the passage ofaquatic life. Cyanide is not known tointerfere with the movement of aquatic species and does not restrict the passage of

.aquatic life (Cyanide SSG Staff Report, Appendix J, Page J-6). Boynton Slough, thereceiving water for discharge point E-001, is a dead-end slough through which thereis nowhere for fish to migrate.

(4) The mixing zone does not adversely impact biologically sensitive, or critical habitats.The Cyanide SSG Staff Report, Appendix J, Page J-6, discusses this issue specificallyfor FSSD and finds that there no anticipated impacts to Delta Smelt habitat, or otherqiologically sensitive habitats.

(5) The cyanide within the mixing zone does not produce undesirable or nuisance aquaticlife. At the concentrations in question, cyanide is not known to produce undesirableor nuisance aquatic life (Cyanide SSG Staff Report, Appendix J, Page J-9).

(6) The cyanide within the mixing zone does not result in floating debris, oil, or scum.,At the concentrations in question, cyanide is not known to result in floating debris,oil, or scum (Cyanide SSG Staff Report, Appendix J, Page J-9).

(7) The cyanide within the mixing zone does not produce objectionable color, odor, taste,. or turbidity. At the concentrations in question, cyanide is not known to produce

objectionaqle color, odor, taste, or turbidity (Cyanide SSG Staff Report, Appendix J,Page J-9). ~ .

(8) The cyanide within the mixing zone does not causy objectionable bottom deposits. Atthe concentrations in question, cyanide is not known to cause objectionable bottomdeposits (Cyanide SSG Staff Report; Appendix J, Page J-9).

(9) The cyanide within the mixing zone does not cause a nuisance. At the concentrationsin question, cyanide is n6t known to cause nuisance (Cyanide SSG Staff Report,Appendix J, Page J-9).

(10) The mixing zone does not dominate the receiving water body or overlap a mixingzone from different outfalls. The proposed mixing zone for FSSD represents only aportion ofthe immediate receiving water body, as noted above, and an even smallerpercentage of the larger water body, Suisun Marsh (Cyanide SSG Staff Report,Appendix J, Page J-9).

(11) The mixing zone is not located at or near any drinking water intake (Cyanide SSGStaff Report, Appendix J, Page J-9).

The mixing zone established by Regional Water Board Resolution R2-2006-0086stretches from the outfall in Boynton Slough to a point approximately 15,000 feet fromthe outfall, between receiving water monitoring points RSW-004 and RSW-005 (Cyanide




SSO Staff Report, Appendix D, Page D-6). The mixing zone was selected to be as smallas practicable while meeting the conditions of SIP section 1.4.2.2. This mixing. zone isbased on the percent effluent modeled at that location, and does not consider degradationof cyanide. The actual cyanide attenuation at this point is therefore likely greater thanthat modeled.

d. Calculation of Pollutant-Specific WQBELs

(1) Copper

(a) Copper \VQC. The site-specific chronic and acute marine WQC for copper fromthe Basin Plan are 6.0 and 9.4 microgranis per liter (!lg/L), respectively,expressed as dissolved metal. Regional Water Board staff converted these WQCto total recoverable metal using the site"specific translators of 0.46 (chronic) and0.64 (acute), as described in IV.C.2,g, above. The tesuhing chronic water qualitycriterion of 13 !lg/L and acute water quality criterion of 15 !lg/L were used toperfonn the RPA.

(b) RPA Results. This Order establishes effluent limitations for copper because theBasin Plan requires that limitations are established due to Reasonable Potentialby Trigger 3.

(c) Copper WQBELs. Final WQBELs for copper, calculated according to SIPprocedures (using'a CV of 0.5 and no dilution credit), are an AMEL of7.9 !lg/Land an MDEL of 15 !lg/L.

(d) Immediate Compliance Infeasible. Statistical analysis of effluent data forcopper, collected over the period of November 2003 to July 2008, shows that the95th percentile (9.0 !lglL) is greater than the AMEL (7.9!lg/L); the 99thpercentile (13 !lg/L) is less than the MDEL (15 !lg/L); and the mean (3.8 !lg/L) isless than the long tenn average of the projectediognoTI11al distribution of theeffluent data set after accounting for effluent variability (5.4 !lg/L). The RegionalWater Board concludes therefore that immediate compliance with these finaleffluent limitations is infeasible. . .

(e) Antibacksliding. Antibacksliding requirements are satisfied as the previousOrder did not include final effluent limitations for copper.

(2) Cyanide

(a) Cyanide WQC. The most stringent applicable WQC for cyanide are an acutecriterion of 9.4 !lg/L and a chronic criterion of 2.9 !lg/L from Basin PlanTable 3-3 for protection of marine aquatic life in San Francisco Bay.

(b) RPA Results. This Order establishes effluent limitations for cyanide because theMEC (l0 !lg/l) exceeds the governing WQC (2.9 !lg/L), demonstratingReasonable Potential by Trigger 1.



ORDER NO. R2-2009-0039NPDES NO, CA0038024

(c) Cyanide WQBELs. Final WQBELs for cyanide, calculated according to SIPprocedures (using a CV ofl.O and a dilution credit of 3.0), are an AMEL of7.4 ).lg/L and an MDEL of 18 ).lg/L at E-001. Final WQBEL~ for cyanide atE-002, E-003 and E-005, calculated using a CVof 1.0 and no dilution credit, areanAMELof2.1 ).lg/LandanMDELof5.3 ).lg/L.

(d) Immediate Compliance Infeasible. Statistical analysis of effluent data forcyanide collected over the period ofNovember 2003 through July 2008 showsthat, for E-001, the' 95th percentile (8.5 ).lg/L) is greater than'the AMEL(7.4).lg/L); the 99th percentile (11 ).lg/L) is less than the MDEL (18 ).lg/L); and the'mean (10 ).lg/L) is greater than the long tenn average of the projected nonnaldistribution of the effluent data set afte:t: accounting for effluent variability(3.8 ).lg/L). However, the 95th percentile is greater than the AMEL (2.1 flg/L), the99th percentile is greater than the MDEL (5.3 ).lg/L),and the mean (10 ).lg/L) isgreater than the long tenn average of the projected nonnal distribution of theeffluent data set after accounting for effluent variability (1.1 ).lg/L). The RegionalWater Board therefore concludes that immediate compliance with these finaleffluent limitations is infeasible.

(e) Need for Cease and Desist Order. Since itis infea~ib1e for the Discharger toimmediately comply with WQBELs for cyanide, the Discharger will likelydischarge in violation of this Order. A Cease and Desist Order will be consideredfor adoption concurrently with tllis Order to ensure that the Discharger achievescompliance. ~

(1) Antibacksliding. Antibacksliding requirements are satisfied because theprevious Order did not include final effluent limitations for cyanide.

(3) Dioxin-TEQ

(a) WQC. The Basin Plan narrative WQO for bioaccumulative substances states:

Many pollutants can accumulate on particulates, in sediments, orbio,accumulate in.fish and other aquatic organisms. Contl~ollable waterquality factors shall not cause a detrimental increase in' concentrations oftoxic substances found in bottom sediments or aquatic life. Effects onaquatic organisms, wildlife, andhuman health will be considered.

-Because it is the consensus ofth6 scientific community that dioxins and furansassociate,with particulates, accumulate in sediments, and bioaccumulate in thefatty tissue of fish and other organisms, the Basin Plan's narrativebioaccumulation WQO is applicable to these pollutants. Elevated levels ofdioxins and furans in fish tissue in San Francisco Bay demonstrate that thenarrative bioaccumulation WQO is not being met. USEPA has therefore included

. Suisun Bay as impaired by dioxin and furan compounds in the current 303(d) Listof waters where WQOs are not being met.

The CTR establishes a numeric WQO for 2,3,7,8-tetrachlorinated dibenzo-p-_dioxin (2,3,7,8-TCDD) of 1.4 x l(i-8 ).lg/L for the protection of human health when


Fairfield-Suisun Sewer DistrictWastewater Treatmem Plant

ORDER NO. R2-2009-0039NPDES NO. CAO038024

aquatic organisms are consumed. When the CTR was promulgated, USEPAstated its suppOli of the regulatIon of other dioxin and dioxin-like compoundsthrough the use of toxicity equivalencies (TEQs) in NPDES permits. ForCalifomia waters, USEPA stated specifically, "If the discharge of dioxin ordioxin-like compounds has reasonable potential to cause or contribute to aviolation ofa narrative criterion, numeric WQBELs for dioxin or dioxin-likecompounds should be included in NPDES pem1its and should be expressed usinga TEQ scheme" [65 Fed. Reg. 31682, 31695 (2000)]. This procedure, developedby the World Health Organization (WHO) in 1998, uses a set of toxicityequivalency factors (TEFs) to conveli the concentration of any congener of dioxinor furan into an equivalent concentration of2,3,7,8-TCDD. Therefore, this Orderuses CTR criterion as a criterion for dioxin-TEQ.

To determine if the discharge of dioxin or dioxin-like compounds from the Planthas reasonable potential to cause or contribute to a violation of the Basin Plan'snalTative bioaccumulation WQO, Regional Water Board staff used TEFs toexpress the measured concentrations of 16 dioxin congeners in effluent andbackground samples as a toxicity weighted concentration equivalent to 2,3,7,8TCDD. These "equivalent" concentrations were then compared to the CTRnumeric criterion for 2,3,7,8-TCDD (1.4 x 10-8 Ilg/L), thus translating thenan-ative bioaccumulation objective into a numeric criterion appropriate for theRPA. Although the 1998 WHO scheme includes TEFs for dioxin-like PCBs, theyare not included in this Order's version of the TEF procedure because the'CTRincludes a specific WQC for total PCBs, which includes dioxin-like PCBs.

(b) RPA Results. This Order establishes efflu.ent limitations for dioxin-TEQ becausethe background concentrationof dioxin-TEQ (4.8 x 10-8 Ilg/L) exceeds thetranslated Basin Plan nalTative objective (the CTR numeric water qualitycriterion) for 2,3,7,8-TCDD (1.4 x 10-8 Ilg/L), and dioxin-TEQ has been detectedin the effluent, demonstrating Reasonable Potential by Trigger 2.

(c) Dioxin-TEQ WQBELs. WQBELs for dioxin-TEQ, calculated using SIPprocedures and the CTR WQC for 2,3,7,8-TCDD as guidance (and a default CVof 0.6 with no dilution credit), are an AMEL of 1.4 x 1O-81lg/L and an MDEL of2.8 x 10-8 Ilg/L.

(d) Compliance Infeasible. The Discharger's Infeasibility Study dated November10, 2008, asselis that the facility cannot immediately comply with these WQBELsfor dioxin-TEQ. With insufficient effluent data to determine the distribution of theeffluent data set or to calculate a mean and standard deviation, feasibility tocomply with final effluent limitations is deten11ined by comparing the MEC(3.0 x 10-9 Ilg/L) to the AMEL (1.4 x 10-8 Ilg/L) and the MDEL (2.8 x 10-8 Ilg/L).Even though the MEC does not exceed the proposed final effluent limits, theDischarger asselis that the variability of dioxin-TEQ measured in the effluentresults in significant uncertainty regarding whether compliance is attainable. TheRegional Water Board concurs with the Discharger's assertion of infeasibilityuntil sufficient effluent data are collected.


Fairfield-Suisun Sewer District. Wastewater Treatment Plant

ORDERNO. R2-2009-0039NPDES NO. CA0038024

(e) Need for a Com,pliance Schedule. This Order includes a compliance schedulebased on a new interpretation of the narrative objective as authorized by StateWater Board Resolution No. 2008-0025, Policy for Compliance Schedules inNational Pollutant Discharge Elimination System Permits, which USEPAapproved on August 27,2008. A compliance schedule will allow time for theDischa:rgerto·coll1plywith these e[fluertt limits, whic:hafebased oli.aneWinterpretation of a narrative objective. The final effluent limits will becomeeffective 10 years from the effective date ofthisOrder. The Regional WaterBoard may amend these limits based on new information or a TMDL fordioxin-TEQ.

(f) Interim Effluent Limitations. The Policy for Compliance Schedules requiresthat compliance schedules include interim limits. This Order establishes ariinterim limit based on the minimum levels (MLs) of all dioxin and furancongeners and their TEFs. The sum of each congener's ML times its TEF is6.3x 10-5 )lg/L. This interim limit is established as a monthly average limit, and it .will remain in effect for ten years following the effective date of this Order.

(g) Antibacksliding. Antibacksliding requirements are satisfied because theprevious Order did not include final effluent limitations for dioxin-TEQ..

(4) Chlorodibromomethane

(a) Chlorodibromometh~meWQC. The most stringent applicable WQC forchlorodibromomethane is the CTR criterion for protection of human health of34 )lg/L.

(b) RPA Results. This Order establishes effluent limitations forchlorodibromomethane because the MEC (44 jlg/L) exceeds the most stringentapplicable criterion (34 )l'g/L), demonstrating reasonable potential by Trigger 1.

(c) Chlorodibromomethane WQBELs. WQBELs for chlorodibromomethane,.. calculated according to SIP procedures (using a. default CV of 0.60 with no

dilution credit),.,are an AMEL of 34 )lg/L and .an MDEL of 68 )lg/L.

(d) Compliance Infeasible. With insufficient data to determine the distribution ofthe data set or to calculate a mean and standard deviation, feasibility to complywith effluent limitations is detennined bycompariri:g the MEC (44 )lg/L) to theAMEL (34 )lg/L) and the MDEL (68 )lg/L). Based on this comparison, theRegional Water Board concludes that the Plant cannot immediately comply with .final WQBELs for chlorodibromomethane.

(e) Need for Cease and Desist Order. Since it is infeasible for the Discharger toimmediately comply with WQBELs for chlorodibromomethane, the Dischargerwill likely discharge in violation of this Order. A Cease and Desist Order will beconsidered for adoption concurrently with this Order to ensure that the Dischargerachieves compliance.


Faitiield-Sllislln Sewer DistrictWastewater Treatment Plant


(f) Antibacksliding. Antibacksliding requirements are satisfied because theprevious pem1it did not cOi1tain final limitations for chlorodibromomethane.

(5) Dichlorobromomethane

(a) DichlorobromomethaneWQC. The most stringentapplicableWQCfotdichlorobromomethane is the CTR criterion for protection of human health of46 Ilg/L.

(b) RPA Results. This Order establishes effluent limitations fordichlorobromomethane because the MEC (64 Ilg/L) exceeds the most stringentapplicable criterion (46 Ilg/L), demonstrating reasonable potential by Trigger 1.

(c) Dichlorobromomethane WQBELs. WQBELs for dichlorobromomethane,calculated according to SIP procedures (using a default CV of 0.60 with nodilution credit), are an AMEL of 46 Ilg/L and an MDEL of 92 Ilg/L.

(d) Compliance Infeasible. With insufficient data to determine the distribution of thedata set or to calculate a mean and standard deviation, feasibility to comply with

.effluent limitations is determined by comparing the MEC (64 IlglL) to the AMEL(46 Ilg/L) and the MDEL (92 Ilg/.L). Based on this comparison, the RegionalWater Board concludes that thePlant cannot immediately comply with finalWQBELs for dichlorobromomethane. .

(e) Need for Cease and Desist Order. Since it is infeasible for the Discharger toimmediately comply with WQBELs for dichlorobromomethane, the Dischargerwill likely discharge in violation of this Order. A Cease and Desist Order willtherefore be considered for adoption concurrently with this Order to ensure thatthe Discharger achieves compliance. .

(f) Antibacksliding. Antibacksliding requirements are satisfied because theprevious pem1it did not contain final limitations for dichlorobromomethane:

(6) Total Ammonia

(a) Ammonia WQC. The Basin Plan contains WQOs for un-ionized 'ammonia of0.025 milligrams per liter (mg/L) as an arumal median and 0.16mg/L as amaximum for Central San Francisco' Bay and upstream reaches. Regional WaterBoard staff translated these WQOs for un-ionized ammonia to equivalent totalammonia concentrations (as nitrogen) since (1) sampling and laboratory methodsare not available to analyze for un-ionized ammonia and (2) thefraction of totalammonia that exists in the toxic un-ionized fonTI depends.on the pH, salinity, andtemperature of the receiving water. To translate the Basin Plan un-ionizedamm011ia objectives, Regional Water Board staff used the following equations todetermine the fraction of total ammonia that would exist in the toxic, un-ionizedfonn in the estuarine receiving water [Ambient Water Quality CriteriaforAmmonia (saltwater) - 1989, EPA Publication 440/5-88-004, USEPA, 1989]:


Fairfield-Suisun'Sewer DistrictWastewater Treatment Plant


For salinity> 10 ppt: fraction ofNH3 = 1+ 10 (pK - pH )

Where:

pK = 9.245 + 0.116*(1) +0;0324*(298-T) + 0.0415*(P)/(T)I = the molal ionic strength of saltwater = 19.9273*(S)/(1000-1.005109*S)S = Salinity (parts per thousand)T = Temperature in KelvlllP = Pressure (one atmosphere)

To determine the fraction of un-ionized ammonia, Regional Water Board staffused site-specific pH, salinity; and temperature receiving water data collected attwo upstream and six downstream monitoring locations from December 2003

,through October 2008. This wide range accounts for some uncertainties resultingfrom the difficulty of collecting representative receiving water samples. Sampleswere not collected at low tide, when the pH values may increase due to naturaldiurnal variability.

To convert the Basin Plan's chronic un-ionized ammonia WQO to an equivalenttotal ammonia concentration, the median un-ionized ammonia fraction calculatedfrom the data set was used. To convert the Basin Plan's acute un-ionizedammonia WQO to an equivalent total ammonia concentration, the 90th percentileun-ionized ammonia fraction calculated from the data set was used. Using the90th percentile and median to express the acute and chronic un-ionized ammoniaWQOs as equivalent total ammonia concentrations is consistent with USEPAguidance, as expressed by USEPA in The Metals Translator: GuidanceforCalculating a Total Recoverable Limit from a Dissolved Criterion (EPAPublication Number 823-B-96-007, 1996). The equivalent total ammonia acuteand chronic WQCs are 5.7 mg/L and 2.1 mg/L, respectively.

(b) RPA Results. The MEC (2.1 mg/L) exceeds the translated WQO (2.05mg/L) forthis pollutant [calculated in (a), above], demonstrating Reasonable Potential byTrigger 1.

(c) Ammonia WQBELs. To set limitations for toxic pollutants, Basin Plan Section4.5.5.2 indicates that WQBELs shall be calculated according to the SIP. Section3.3.20 of the Basin Plan refers to ammonia as a toxic pollutant; therefore, it isconsistent with the Basin Plan to use the SIP methodology to determine and .establish effluent limitations for ammonia. The total ammonia WQBELs,calculated according to SIP procedures (using a CV of 1.36 with no dilutioncredit), are an AMEL of2.0mg/L and anMDEL of5.7 mg/L. To calculate thesetotal ammonia limits, some statistical.adjustments were made because the BasinPlan's chronic WQO for'un-ionized ammonia is based on an annual median,while chronic criteria are usually based on a 4-day ayerage; also, the SIP assumesa monthly sampling frequency of 4 days per month to calculate effluentlimitations based on chronic criteria. To use the SIP methodology to calculateeffluent limits for a Basin Plan objective that is based on an annual median, anaveraging period of365 days and a monitoring frequency of 3.0 days per month

AttacbmentF -Fact Sheet F-34

Fairfield-Suisun Sewer DistrictWastewater Treatment Plall!


(the maximum daily sampling frequency in a month since the averaging p~riod fora chronic criterion is longer than 30 days) were used. These statisticaladjustments are supported byUSEPA's FVatet Quality Criteria; Notice ofAvailability; 1999 Update ofAmbient Water Quality Criteria for Ammonia,published on December 22, 1999, in the federal Register.

These newly calculated WQBELs are higher than the perfom1ance-based limits inthe previous permit

(d) Compliance Feasible. Statistical analysis of effluent data for total ammoniacollected over the period ofNovember 2003 ·to July 2008, shows that the 95thpercentile (2.1 mg/L) is slightly greater than the AMEL (2.0 mg/L); the 99thpercentile (2.1mg/L) is less than the MDEL (5.7 mg/L); and the mean (0.45mg/L) is less than the long tem1 average of the projected lognormal distribution. ofthe effluent data set after accounting for effluent variability (0.88 mg/L).

The Discharger was able to comply with more stringent effluent limitations in theprevious pen11it (Order No. R2-2003-0072), over the course of the pen11it ten11from November 2003 to August 2008. Based on this comparison, the RegionalWater Board concludes that immediate compliance with the WQBELs for totalammonia is feasible.

(e) Antibacksliding. Theprevious pem1it included an AMEL of 2.0mg/L and anMDEL of 4.0 mg/L, as technology-based limitations. The newly calculatedlimitations are higher than the effluent limitations in the .previous Order. Tocomply with the antibacksliding requirements, this Order retains the previouslimits for total ammonia.

e. Effluent Limit Calculations

The following table shows the WQBEL calculations for copper, cyanide, dioxin-TEQ,chlorodibromomethane, dichlorobromomethane, BEHP, and ammonia.



Table F-ll. Effluent Limit Calculations


CyanideCyanide (E- (E-002,E-003, Dioxin- Chlorodibro- Dichlorohro- Total Ammonia Total Ammonia

PRIORrTY POLLUTANTS CODDer 001) E-005) TEQ momethane momethane (acule) (chroDic)

Unils uo/L u~/L Ul,/L uI'/L Ul'/L u"IL me/LN mo/LNBP Basin Plan Basin Plan

Basis and Criteria tvne BP SSOs BP SSOs BP SSOs Narrative CTRHH CTRHH Anuatie Life Anuatie Life

Criteria -Acute ----- ---- ----- ----- ----- -- - 5.67 -----Criteria -Chronic ----- ---- ---- ---- ----- ---- ----- 2.05SSO Criteria -Acute 9.4 9.4 9.4 ----- - -- .-.--SSG. Criteria -Chronic 6.0 2.9 2.9 ---- ----- -- -Water Effects ratio (WER) 2.4 I I 1 I I 1 1Lowest WQO 13.0 2.9 2.9 1.4E-08 34 46 5.67 2.05Site Spccific Translator - MDEL 0.64 ---- ---- ---- ----- ----- ----Site Specific Translator - AMEL 0.46 ----- - -- - ----- --- ---- -Dilution Factor (D) (if annlicable) 0 3 0 0 0 0 0 0No. of samnles pet month 4 4 4 4 4 4 4 30Aguatic lifc criteria analysisrequired? (YIN) Y Y Y' N N N Y YHH critcria analysis Teouircd? (YIN) N Y y. Y y y N N

Applicable Acute WQO 15 9.4 9.4 5.67, Applicable Chronic WQO J3 2.9 2.9 2.05 '

HH criteria ----- 220000 220000 1.4E-08 34 46Background (Maximum Conc forAouatic Life calc) 9.9 0.5 0.5 4.8£-08 ---- -- - 0.6 0.18Background (Ayerage Conc forHuman Health calc) ---- 0.5 0.5 3.4£-08 0.05 0.05Is the pollutant on the 303d list I(YIN)? N N ,N Y N N N N

ECA acute 14.7 36 9.4 6ECA chronic 13.0 10 2.9 2.1

ECAHH 879999 220000 1.4E-08 34 46

No. of data points <10 or at least "

80% of data reporled non detect?(YIN) N N N Y Y Y N NAyo ofeffluent data noints 3.8 3.0 3.0 0.45 0.45Std Dev of effluent data points 1.9 2.9 2.9 0.61 0.61CY calculated 0.50 1.0 1.0 N/A N/A N/A 1.36 1.36CY (Selected) - Final 0.50 1.0 1.0 0.6 0.6 0.6 1.36 1.36

ECA acute mu1t99 0.37 0.21 0.21 0.156ECA chronic mu1t99 0.58 0.38 0.38 0.849LTA acute 5.4 7.5 1.9 0.9 ,LTA chronic 8 3.8 J.] 1.74minimum ofLTAs 5.4 3.8 l.J

,0.88 1.74

AMELmult95 1.5 1.9 1.9 1.6 1.6 1.6 2.28 ----

MDELmult99 2.7 4.8 4.8 3.1 3.J 3.1 6.41 ----

AMEL (aq life) 8 7.4 2.1 2.02 - --MDEL(ao life) IS 18.4 5.3 5.67 ----

MDELIAMEL Multinlier 1.85 2.50 2.50 2.01 2.01 2.01 2.81 ----AMEL (human hlth) 879999 220000 0.000 34.000 46.000MDEL (human h1th) 2202700 550676 0.000 68.210 92.285

minimum of AMEL for Ag. life ysHH 8 7.36 2.11 0.0 34.0 46.0 ? ---minimum ofMDEL for Ag. Life YS

HH IS 18.42 5.29 0.0 68.2 92.3 6 ----

Current limit in pcrmit (30-dayaverage) _.-- ---- --- ---- --- ---- ----- ----

12.3Current limit in permit (dailv) (Intcrim) 32 (Interim) , 32 (Interim) ---- ---- 75 (Interim) ._.- ----

Final limit - AMEL 7.9 7.4 2.1 1.4E-08 34 46 2.0 -----Final limit - MDEL IS 18 5.3 2.8E-08 '68 92 5.7 ----Max Effl Cone (MEC) 9.2 10 10 3.0E-09 44 64 2.J 2.1

I.



5. 'Whole Effluent Acute Toxicity

ORDER NO. R2-2009-0039 .NPDES NO. CA0038024

a. Permit Requirements. This Order includes effluent limitations for whole effluent acutetoxicity that are based on Basin Plan Table 4-3 and are unchanged from the previouspemlit. Compliance evaluation is based on 96-hour static-renewal bioassays. Allbioassays shaUbe performed according to theUSEPA-approvedmethodin40~CERPart136, currently Methodsfor Measuring the Acute Toxicity of~ffluents and ReceivingFVater, 5th Edition.

b. Compliance History. The Discharger's acute toxicity il10nitoring data show thatbioassay results from November 2004 to August 2008 ranged from 95% to 100% survival

.meeting both the II-sample 90th percentile limitation and the an II-sample medianlimitation. Therefore, there have been no acute toxicity effluent limitatio1;1 violations.

c. Ammonia Toxicity. Uthe Discharger can demonstrate to the satisfaction of theExecutive Officer that toxicity exceeding limitations in this Order is caused by ammonia,and that the ammonia in the discharge does not exceed ammonia effluent limitations, thensuch toxicity does not constitute a violation of the effluent limitations for whole effluenttoxicity. If ammonia toxicity is verified by a Toxicity Identification Evaluation (TIE),the Discharger may use an adjusted protocol approved by the Executive Officer for.routine bioassay testing.

6. Whole Effluent Chronic Toxicity.

a. Permit Requirements. This Order includes requirements for chronic toxicitymonitoring based on the Basin Plan naJTative toxicity objective. This pemlit includes theBasin Plan nanative toxicity objective as monitoring "triggers," which, when exceeded,initiate accelerated monitoring requirements, including in some circumstances a clu'onictoxicity reduction evaluation (TRE). These pennit requirements for chronic toxicity areconsistent with the CTR and SIP requirements.

b. Chronic Toxicity Triggers. This Order iricludes chronic toxicity triggers of 1.0 chronictoxicity unit (TUc) asa three sample median, and a single sample maximum of2.0 TUc.These triggers are based on Basin Plan Table 4-5.

c. Monitoring History. The Discharger's chronic toxicity monitoring data from February J

2005 through July 2008 show that 10 out of 16 chronic toxicity results exceeded both thesingle sample maximum and the three sample median effluent "triggers." TheDischarger's laboratory conducted Phase I TIE studies to identify the source of toxicity.The studies indicated that the toxicity was related to chelatable constituents and non-polarorganics (NPOs), but that the cause could not be isolated. The detected toxicity wasreduced in four of six trials by extracting NPOs from the effluent samples using solidphase extraction (SPE) columns. However, no toxicity was detected when the eulatefrom the SPE colunuls was tested. The laboratory also perf0TI11ed toxicity tests of thechelatable process chemicals used by the Discharger (alum, ferric chloride, andpolymers). These tests showed that, in the amounts used by the Discharger, only alumwas a candidate toxicant; however, suspending the use of alum for three months had noeffect on the toxicity detected in effluent samples. The Dis"dlarger's laboratory concludedthat the cause of toxicity to the test species Haliotos rL!fescens (red abalone) was related

. Attachment F - Fact Sheet F-37

Faidield-Suisun Sewer DistrictWastewater Treatment Plant


to NPOs, chelatable substances, and other unidentified factors, and that further TIEtesting was unlikely to provide more information.

The laboratory then conducted two species screening tests. Of the six species tested, redabalone was the only species that detected toxicity in the Discharger's effluent. The labtherefore concluded that the toxicitywas .species-specific to red abalone, Based on-the results of these species screening tests, the laboratory recommended replacing redabalone with mysidopsis bahia (mysid shrimp) as the test species because mysid shrimpis a sensitive and reliable test species, and is an appropriate species for evaluatingdischarges to estuarine environments such as Suisun Slough, Suisun Marsh, andLedgewood Creek. The test results and recommendations are documented in Phase IToxicity Identification Evaluation: Identification ofthe Cause ofFaiJfield-SuisunWastewater Treatment Plant EjJluent Chronic Toxicity to Red Abalone (Haliotirufescens), prepared by AQUA-Science Environmental Toxicology Consultants of Davis,California, dated June 5, 2007.

d. Screening Phase Study. The Discharger is required to conduct a chronic toxicityscreening phase study, as described in Appendix E-l of the MRP (Attachment E), prior tothe next permit issuance.

7. Temperature

Ledgewood Creek 'supports warm and cold water habitat beneficial uses; therefore, specifictemperature objectives apply. Regional Water Board staff analyzed whether there could beany reasonable potential that Ledgewood Creek (outfall E-005) could exceed the Basin Planand Thermal Plan temperature objectives. Effluent temperature data from the BoyntonSlough outfall (E-OOl) and background data from receiving water nlonitoring pointRSW-007 (formerly CR-l) were compared to the Thermal Plan's objectives for newdischarges to estuaries (the Thermal Plan's requirements areslightly more stringent that theBasin Plan's requirement, so the analysis focused on the Thermal Plan). The Thermal Plan'sobjectives are:

a. The maximum temperature shall not exceed the natural receiving water temperature bymore than 20 degrees Farenheit (OF).

b. Elevated temperature waste discharges either individually or combined with other.discharges shall not create a zone, defined by water temperatures of more than 1°F abovenatural receiving water temperature, which exceeds 25 percent of the cross-sectional areaof a main river channel at any point.

c. No discharge shall cause a surface water temperature rise greater than 4°F above thenatural temperature of the receiving waters at any time or place.

d. Thermal waste discharges having a maximum temperature greater than 4°F above the. natural temperature of the receiving water are prohibited.

e. Additional limitations shall be imposed when necessary to assure protection ofbeneficialuses.

The analysis is based on effluent temperature data from E-OO I because there has been nodischarge from E-005 yet. The temperature of the E-OO1 discharge should be representativeof that from E-005 since both will undergo the same treatment process. The analysis isfurther based on background data from RSW-007 because it is the closest background




monitoring point to E-005. RSW-007 is located in Peytonia Slollgh downstream ofE-005and is already used to evaluate background receiving water conditions.

Effluent temperature data collected between November 2003 and August 2008 wereconsidered (this is the same timeframe used for inorganic pollutants), excluding the

.maximumandminimumobservationsof35.6 and 97 's°F;whichare extreme values that .appear to be incorrect. The mean effluent temperature was 69°P and the standard deviation'5°F.

The effluent temperature range (54 to 82°P ) was within 200 P of the receiving watertemperature range (51 to 74°P). The mean effluent temperature (69°P) was also within 20 0 Pofthe mean receiving water temperature (63°P). No independent effluent temperaturemeasured concurrently with receiving water temperature exceeded the receiving watertemperature by more than 20oP. Therefore, there is no reasonable potential that the dischargecould exceed Thermal Plan objective "a," above.

The discharge would not exceed Them1al Plan objective"b" because Ledgewood Creek isnot a main river channel.

\

Based on data for E-OOl, it·is unlikely that the E-005 discharge will exceed Thermal Plan·objective "c." Specifically, the E-OOI discharge has not caused any violations of OrderR2-2003-0072's narrative receiving water temperature limit in Boynton Slough. E-005temperature should be identical to E-OO l's but a direct analysis caimot be performed at thistime because data on temperature changes in Ledgewood Creek due to the E-005 dischargeare unavailable as no discharge from E-005 ha~ occurred to date.

The E-005 discharge is not a them1al waste as defined by the Them1al Plan and thusobjective "d" above does hot apply.

Because some of the analyses described above are indirect, we luive revised the tentativeorder to require a study focused on effluent and receiving water temperature to confirm theconclusions. .

D. Antidegradation

1. Effluent Limitations Retained fro.m Order No. R2-200J-OOn. Limitations for thefollowing parameters are retained and are unchanged from Order No. R2-2003-0072:

• Oil and grease• Turbidity

• pH• BODs and TSS• Total residual chlorine• 85% removal requirement for BOD and TSS• Acute toxicity• Ammonia



ORDER NO, R2-2009-0039NPDES NO, CAO038024

Retaining effluent limitations for these parameters in this Order ensures that these limitationsare at least as stringent as those in Order No. R2-2003-00n, meeting antidegradationrequirelnents.

2. New Final Effluent Limitations. This Order establishes new final conc~ntration-based

limitations for the followiJigparameters thatwere not contained in Order No. R2-'2003-'OOn.

• Copper• Cyanide• Dioxin-TEQ• Chlorodibromomethane• Dichlorobromomethane• Enterococcus Bacteria

The establishment of effluent limitations for these poilutants effectively creates limitationsthat are more stringent than in Order No. R2-2003-00n, therefore meeting antidegradationrequirements. The new final limits for copper and dichlorobromomethane are higher than theinterim limits in Order No. R2-2003-007£, which will be discussed below.

3. More Stringent EffluenfLimitations'. This Order does not establish limits more stringentthan those limitations in OrderNo. R2-2003-00n.

4. Effluent Limitations Not Retained from Order No. R2-2003-0072. This Order .does notretain limitations for the following parameters:

• . Settleable matter• Mercury• Nickel• Cadmium• Chromium(VI)• Bis(2-ethylhexyl)phthalate• Total coliform bacteria

This Order does not retain effluent limitations for settleable matter. For the Plant, like otherfacilities achieving secondary or more advanced levels of treatment, compliance with the.requirements of 40 CFR 133 and Basin Plan Table 4-2 will also ensure removal ofsettleablesolids to acceptably low levels - below 0.1 mL/L-hr (30-day average) and 0.2 mL/L-hr (daily

I •

maximum). Therefore, no degradation of water quality will occur.

Order No. R2-2003-00n included effluent limitations for cadmium, chromium(VI), and·nickel; however, because the RPA showed that discharges from the Plant no longerdemonstrate a reasonable potential to cause or contribute to exceedances of applicable waterquality criteria for these pollutants, this Order does not retain these limitations from OrderNo. R2-2003-00n. Elimination ofWQBELs for cadmium, chromium(VI), and nickel isconsistent with State Water Board Order WQ 2001-16 that incorporates antidegradationrequirements.




The previous permit included an interim effluent limitation for mercury, which is notretained by this Order, because discharges of mercury to the San Francisco Bay are nowregulated by' Regional Water Board Order No. R2-2007-0077, which became effective March1,2008. Order No.R2-2007-0077 was established to be consistent with antI-backsliding·andantidegradation require111ents.

The previous pem1it included an interim effluent limitation for bis(2-ethylhexyl)phthalate,which is not retained by this Order. The Discharger was able to demonstrate through its .Bis(2-ethylhexyl)phthalate Laboratory Analysis Study, that data collected during its permitterm prior to the Study were contaminated. Therefore, Regional Water Board staff used onlyeffluent data collected using clean sampling tec1uliques for the RPA. Since the RPA showedthat discharges from the Plant no longer demonstrate a reasonable potential to cause orcontribute to exceedances of applicable water quality criteria for these pollutants, this Orderdoes not retain these limitations from Order No. R2-2003-00n. Elimination ofWQBELs forbis(2-ethylhexyl)phthalate is consistent with State Water Board Order WQ 2001-16 thatincorporates antidegradation requirements.

The limitations for total colifom1 bacteria are not retained because they have been replacedwith effluent limitations for enterococcus bacteria, which are equally protective of beneficialuses.

5. Effluent Limitations Higher Than in Order No. R2-2003-00n.· Limitations for thefollowing parameters are higher than in the previous Order:

• Copper• Dichlorobromomethane

The effluent limitations for copper based on site-specific objectives (SSOs) are higher thanthe interim limitation for copper contained in the previous Order. The standards settingprocess for the copper SSOs addressed anti-degradation, concluding that water quality wouldnot be degraded (see Copper Site-Specific Objectives in San Francisco Bay: Proposed BasinPlan Amendment and Draft StaffReport, June 6, 2007). This conclusion is based on theimplementation of a Copper Action Plan. Section VI.c. 7 of this Order requires such anaction plan.

The effluent limitations for dichlorobromomethane are higher than the interim limitation fordichlorobromomethane contained in the previous Order. The current advanced secondarylevel of treatment will remain unchanged, and the Discharger plans on implemeliting UVdisinfection; which will add an additional level of treatment. Therefore, degradation of waterquality is unlikely.

6. Flow Increase. Consistent with Order No. R2-2006-0045, this Order allows for an increasein the average dry weather discharge rate from 17.5 MGD to 23.7 MGD upon the Dischargermeeting the conditions described in section VI.C.2.e of this Order, and upon Executive.Officer approval. To support the increase in effluent flow, the Discharger prepared anantidegradation analysis in accordance with guidance contained in State Water BoardAdministrative Procedures Update No. 90-04. The analysis indicated that. the increase inpennitted dry weather discharge is necessary to accommodate planned growth within the




Discharger's service area and is otherwise consistent with federal and State antidegradationpolicies. The increased discharge will have no measurable effect on the water quality ofSuisun Slough, Grizzly Bay, Suisun Bay, or other segments of greater San Francisco Bay.

The Regional Water Board has detennined that the increase in effluent flow will be consistentwith applicable3.iHidegradatiol1 requiremehtsOf StateWatetBoardResbltitibiiN6: 68=16, aswell as USEPA policy established at 40 CFR 131.12. In accordance with State Water BoardResolution No. 68-16 and USEPA policy regarding antidegradation, water quality is to bemaintained where water quality exceeds levels necessary to support propagation of fish,shellfish, and wildlife and recreation, unless the Regional Water Board finds:

1. That allowing lower water quality is necessary to accommodate important economic orsocial developmentin the area In which the waters are located,

2. That applicable water quality criteria and objectives shall be achieved,

3. That existing beneficial uses of the receiving water will be fully protected, and

4. That the highest statutory and regulatory requirements for point source discharges to thereceiving water are being achieved; and that all cost-effective and reasonable bestmanagement practices for non-point source discharges to the receiving water are beingachieved.

As described above, the expansion of the Plant is necessary to support growth within its serviceareas. Effluent limitations and specifications contained in the Order will as.sure that applicablewater quality criteria and objectives of the receiving waters are being achieved, and that thebeneficial uses of these receiving waters are being fully protected.

Through its issuance ofthis NPDES pennit, the Regional Water Board continues to implementthe highest statutory and regulatory requirements applicable to such discharges pursuant to thefederal Clean Water Act and the California Water Code and regulations implementing thosestatutes.

V. RATIONALE FOR RECEIVING WATER LIMITATIONS

Receiving water limitations are retained from Order No. R2-2003-00n and reflect applicable water·quality standards from the Basin Plan.

VI. RATIONALE FOR MONITORING AND REPORTING REQUIREMENTS

The principal purposes of a monitoring and reporting program by a discharger are to:

• document compliance with waste discharge requirements and prohibitions established by theRegional Water-Board;

• facilitate self-policing by the discharger in the prevention and abatement of pollution arisingfrom waste discharge;.

• develop or assist in the development of limitations, discharge prohibitions, national standards ofperfonnance, pretreatment and toxicity standards, and other standards; and -


Faitfteid-Suisull Sewer DistrictWastewater Treatment Plant

.ORDER NO. R2-2009-0039NPDES NO. CA0038024

• prepare water and wastewater quality inventories.

The Monitoring and Reporting Program (MRP) is a standard requirement in"almost all NPDESpem1its the Regional Water Board issues, including this Order. It contains definitions oftenns,specifies general sampling and analytical protocols, and sets out requirements for reporting of spills,violations, and routine monitoring data in accordance with NPDES regulations; the GWG; and·Regional Water Board policies. The MRP also defines the sampling stations and frequency, thepollutants to be monitored, and additional reporting requirements. Pollutants to be monitoredinclude all parameters for which effluent limitations are speCified. Monitoring for additionalconstituents, for which no effluent limitations are established, is also required to provide data forfuture RPAs.

A; Influent Monitoring

Influent monitoring requirements for BODs and TSS allow detem1ination of compliance with thisOrder's 85 percent removal requirement. Influent flow monit0l1ng requirements are retained fromthe previous pennit.

B. Effluent Monitoring

.The MRP retains most effluent monit0l1ng requirements from the previous permit. Changes ineffluent monitoring at EFF-001-D are summarized as follows.

• Monitoring for settleable matter is no longer required because the effluent limitation for thisparameter is not retained in this Order. .

• Monthly routine monitoring for cadmium, chromium(VI), zinc, and lead i$ no longer requiredbecause these pollutants no longer demonstrate r,easonable potential. Monthly monitoring formercury is no longer required because the discharge of mercury is now regulated by RegionalWater Board Order No. R2-2007-0077.

)

• This Order requires routine effluent monit0l1ng for copper, cyanide, dioxin-TEQ,chlorodibromomethane, dichlorobromomethane, and ammonia (priority toxic pollutants witheffluent limitations established by this Order). Monitoring for all other priority toxic pollutantsis to be conducted in accordance with methods described in the August 6, 2001, Letter.

o.J • Monitoring for cyanide is required at E-OO1 and E-005, at a pointafter full treatment 'anddechlorination, and prior to contact with Boynton Slough.

• Monitoring for enterococcus bacteria is required to detem1ine compliance with newlyestablished limitations for enterococcus bacteria.

Effluent monitoring requirements at E-001, E-002, E-003, and E-005 are retained from OrderNo. R2-2003-00n, as amended by Order No. R2-2006-0045.

c. Whole Effluent Toxicity Testing Requirements

1. Acute Toxicity. Monthly 96-hour bioassay testing is required at E-OO 1 or E-005, todernonstrate compliance with the effluent limitation for acute toxicity.




2. Chronic Toxicity. Chronic whole effluent toxicity testing is required at E-OOI or E-OO\ .once per quarter, in order to demonstrate compliance with the Basin Plan's narrative toxicityobjective.

D. Reclamation Monitoring Requirements

See Reclamation Order No. 91-147.

E. Receiving Water Monitoring,

Most receiving water monitoring requirements are retained from the previous permit. This Orderestablishes new monitoring locations in Ledgewood Creek to characterize receiving waterconditions for the new discharge at Discharge Point 005. Monitoring requirements for pH,temperature, salinity, and ammonia in receiving waters are required for determination of sitespecific ammonia WQCs. Suisun Marsh is 303(d) listed for metals, low dissolved oxygen,salinity, and nutrients. Receiving water monitoring for these parameters is required to monitorthe status of impairment in the receiving waters. Monitoring requirements for turbidity, specificconductivity, chlorophyll-a, and water depth in receiving waters have not been retained.

-F. Other Monitoring Requirements

1. Pretreatment Requirements. Pretreatment monitoring requireinents for the influent,effluent, and biosolids are retained from the previous permit and are required to assesscompliance with the Discharger's USEPA approved pretreatment program.

2. Sludge Monitoring. Sludge monitoring is required pursuant to 40·CFR Part 503.

VII. RATIONALE FOR PROVISIONS

A. Standard Provisions (provision VI.A)

Standard Provisions, which in accordance with 40 CFR l22.4land 122.42 apply to all NPDESdischarges and must be included in every NPDES permit, are provided in Attachments D and Gof this Order. The Discharger must comply with all standard provisions and with those additionalconditions that apply under 40 CFR 122.42.

40 CFR 122.41 (a)(l) and (b) through (n) establish conditions that apply to all state-issuedNPDES permits. These conditions mustbe incorporated into the pemlits eitheJ;' expressly or byreference. If incorporated by reference, a specific citation to the regulations must be included inthe Order. Section l23.25(a)(l2) allows the state to omit or modify conditions to impose morestringent requirements. In accordance with section 123.25, this Order omits federal conditionsthat address enforcement authority specified in sections l22.4l(j)(5) and (k)(2) because theenforcement authority under CWC is more stringent. In lieu of these conditions, this Orderincorporates by reference CWC section 13387(e).

B. Monitoring and Reporting Requirements (Provision VI.B)

The Discharger is required to monitor the permitted discharges in order to evaluate compliance with. permit conditions. Monitoring requirements are contained in the MRP (Attachinent E) and


Fairfield-Suisun Sewer DistrictWast.ewater Treatment Plant


I

Standard Provisions and Self-Monitoring Program(SMP), Part A (Attachment G). This provisionrequires compliance with these documents and is based on 40 CFR 122.63 and CWC sections13267 and 13383.SMP, Part A, contains standard requirements in almost all NPDES pemlits issuedby the Regional Water Board, including this Order. They contain definitions of terms, specifygeneral sampling and analytical protocols, and set out requirements for reporting spills, violations,

. androutinemonitoringdata in accordancewithNPDES regulations, the CWC,al1dRegionaIWater'Board policies. The MRP (Attachment E) contains a sampling program specific for the Plant. Itdefines sampling stations and frequencies, the pollutants to be monitored, and additional reportingrequirements. Pollutants to be monitored include all parameters for which effluent limitatiQns are'specified. Monitoring for additional constituents, for which no effluent limitations are established,is also required to provide data for future RPAs.

C. Special Provisions (Provision VI.C)I

1. Reopener Provisions

These provisions are based on 40 CFR 123 and allow modification of this Order and itseffluent limitations as necessary in response to updated WQOs that may be established in the'future and other circumstances.

2. Special Studies and Additional Monitoring Requirements

a. Effluent Characterization Study: This Order does not include effluent limitations forconstituents addressed in the August 6, 2001, Letter that do not demonstrate ReasonablePotential, but this provision requires the Discharger to continue monitoring for thesepollutants as described in the August 6, 2001, Letter and as specified in the MRP. Ifconcentrati011s of these constituents increase significantly, the Discharger is required toinvestigate the source of the increases and establish remedial measures if the increasesresult in reasonable potential to cause or contribute to an excursion above the applicableWQOs. This provision is based on the Basin Plan and the SIP.

b. Ambient Background Receiving Water Study: This provision is based on the Basin Plan,the SIP, and the August6, 2001, Letter for priority pollutant monitoring. As indicated inthis Order, this requirement may be met by participating in a collaborative study.

c...Diurnal Ammonia Study: This provision is needed to characterize diurnal variabilitythroughout the day ofreceiving water quality parameters (pH, salinity, hardness,temperature, dissolved oxygen, and ammonia). This information will be used to confirmwhether the ammonia limits are sufficiently protected. As indicated in this Order, thisrequireInent includes submittal of a study plan, implementation of the study plan, arid afinal report.

d. Updated Technical Report on Recycled Wat.er Use and Discharge Impacts on BeneficialUses: This provision is needed to update our understanding of any impacts of the existingand planned discharges on Boynton Slough and Ledgewood Creek, and to provide a basisfor granting exceptions to Basin Plan prohibitions in future pemlit reissuances. Thisrequirement includes submittal of a study plan, implementation of the study plan, andsubmittal of a final report.




e. Ledgewood Creek Temperature Study: This study is required to confiml the results of theRPA for temperature. Some of the analysis was indirect due a lack of data on dischargesfrom E-005. Since the Discharger plans to use E-005 only in the case of high wet-weatherflows that exceed the capacity of E-OO 1, opportunities to collect representative data maybe limited. The Discharger shall propose a study plan that entails studyi:ug temperatureimpacts to the receiving water to the extent possible given the discharge frequency fromE-005. It will not be a violation of this Order if data collection is limited due to lowdischarge frequency from E-005 (or ifno data is collected because no discharge occurs).Since any discharges from E-005 are likely to occur during nomlally colder wet weathermonths, the data collected may likely not represent year-round receiving waterconditions. The Regional Water Board shall take the amount of data collected intoaccount when analyzing reasonable potential for temperature at the next pemlit

. .relssuance.

f. Optional Mass Offset Plan: This option is provided to encourage the Discharger tofurther implement aggressive reduction of mass loads to San Francisco Bay. If theDischarger wishes to pursue a mass offset program, a mass offset plan for reducing303(d)-listed pollutants needs to be submitted for Regional Water Board approval. TheRegional Water Board may consider any proposed mass offset plan and amend this Order

. accordingly.

.g. Optional Site-Specific Translator Study: This option is provided to encourage theDischarger to continue to collect receiving water data to augment the current set used todevelop site-specific translators to ensure that the translators reflect actual, current sitespecific conditions.

h. Dry Weather Flow Capacity Analysis: This provision is required to support theDischarger's anticipated Plant expansion and the construction of a new outfall toLedgewood Creek. The Discharger has previously submitted an Environmental ImpactReport (EIR) and an Antidegradation Analysis to the Regional Water Board forconsideration. The outfall construction was completed in August 2008, and the treatmentplant expansioil is expected to be complete by September 2009. This provision requiresthe Discharger to submit documentation. that demonstrates that actual treatment capacityonce completed is 23.7 MGD; certification that the Plant facilities have been completedas designed and are available to use; and updates to the contingency plan and theoperations and maintenance manual. Upon Executive Officer approval of these remainingdocuments, the pemlitted dry weather flow will increase from 17.5 MGD to 23.7 MGD.

3. Best Management Practices and Pollution Minimization Program

This provision is based on Basin Plan Chapter 4 and SIP Section 2.4.5.

4. Construction, Operation, and Maintenance Specifications

a. Wastewater Facilities, Review and Evaluation, Status Reports: This provision is based onOrder No. R2-2003-00n and the Basin Plan.

b. Operations and Maintenance Manual, Review and Status Reports: This provision isbased on the Basin Plan, the requirements of 40 CFR 122, and Order No. R2-2003-00n.



ORDER NO. R2-2009-0039NPDES NO. CA0038024. .

c. Contingency Plan, Review and Status Reports: This provision is based on the Basin Plan,the requirements of 40 CPR 122, and Order No. R2-2003-0072. See Section Vl.C.4.c ofthis Order for specific requirements. .

5. Special Provisions for Municipal Facilities (POTWs Only)

a. Pretreatment Program: This provision is based on 40 CFR 403 and is can-ied over fromthe previous permit.

b. Sludge Management Practices Requirements: This provision is based on Basin PlanChapter 4, and 40 CFR §§257 and 503, and the previous pennit.

c. Sanitary Sewer Overflows and Sewer System Management Plan: This provision is toexplain this Order's requirements as they relate to the Discharger's conveyance system,and to promote consistency with the State Water Board's Statewide General WasteDischarge Requiretnents for Sanitary Sewer Overflows and its associated Monitoring andReporting Program (Order No. 2006-0003-DWQ).

6. .Compliance Schedule

The compliance schedule and the requirement to submit reports on further measures toreduce concentrations of dioxin-TEQ to ensure compliance with final limits are based onState Water Board Resolution No. 2008-0025, Policyfor Compliance Schedules in NationalPolhttant Discharge Elimination System Permits,which was approved by the U.S. EPA onAugust 27, 2008. This Order includes a compliance schedule and discharge specifications fordioxin-TEQ.

A maximum compliance schedule is reasonable for dioxin-TEQ because of the considerable'uncertainty in detem1ining effective measures (e.g., pollution prevention, treatment upgrades)that should be implemented to ensure compliance with final limitations. In the RegionalWater Board's view, it is appropriate to allow the Discharger sufficient time to exploresource control measures before requiring it to propose further actions, such as treatment plantupgrades, that are likely to be much more costly. This approach is supported by the BasinPlan (section 4.13), which states, "In general, it is often more economical to reduce overallpollutant loading into treatment systems than to install complex and expensive technology atthe plant." .

7. Copper Action Plan

This Order requires the Discharger to implement monitoring and surveillance, pretreatment,source control, and pollution prevention for copper in accordance with the Basin Plan. TheBasin Plan contains site-specific water quality objectives for copper in all segments of SanFrancisco Bay. The water quality objectives are 6.0 !lg/L dissolved copper as a 4-dayaverage, and 9.4 !lg/L dissolved copper as a I-hour average. The Basin Plan also requires animplementation plan to ensure no degradation of water quality. .



8. Cyanide Action Plan


The Basin Plan requires a Cyanide Action Plan to ensure compliance with antidegradationpolicies. The Order requires the Discharger to implement monitoring and surveillance,pretreatment, source control, and pollution prevention for cyanide in accordance withRegio:nal"WatecBoardletterdated August"8;2008; entitled, Alternate CyanideEfjluent .Limitations Effective, Requirementfor Cyanide Action Plan, "andRequ~rement for InfluentMonitoring. Task 1 of the letter requires the Discharger to submit an inventory of potentialcontributors of cyanide to the treatment plant (e.g., metal plating operations, hazardous wasterecycling, etc.). Task 2 of the letter requires implementation of the Cyanide Action Plan Task3 requires the Discharger to report on the implementation status.

VIII. PUBLIC PARTICIPATION

The Regional Water Board is considering the issuance of Waste Discharge Requirements (WDRs)that will serve as an NPDES pennit for the Plant. As a step in the WDR adoption process, theRegional Water Board developed tentative WDRs. The Regional Water Board encourages publicparticipation in the WDR adoption process.

A. Notification of Interested Parties

. The Regional Water Board notified the Dischargers and interested agencies and persons of its intentto prescribe WDRs for the discharge and has provided them with an opportunity to submittheirwritten comments and recommendations. Notification was provided through the Vallejo Times- .Herald.

B. Written Comments

Staff determinations are tentative. Interested persons '!Ie invited to submit written commentsconcerning these tentativeWDRs. Comments must be submitted either in person or by mail to theattention ofAdrienne Miller at the Regional Water Board at the address above on the cover page ofthis Order.

To be fully responded to by staff and considered by the Regional Water Board, written commentsmust be received at the Regional WaterBoard offices by 5:00 p.rn. on March 2, 2009.

C. Public Hearing

The Regional Water Board will hold a public hearing on the tentative WDRs during its regularBoard meeting on the following date and time and at the following location:

Date:Time:Location:

Contact:

April 8, 20099:00 amElihu Harris State Office Building1515 Clay Street, 1st Floor AuditoriumOakland, CA 94612

Adrienne Miller, (510) 622-2415, email admiller(a{waterboards.ca.gov


Fairfield-Suisun Sewer District'Wastewater Treatment Plant


Interested persons are invited to attend. At the public hearing, the Regional Water Board will heartestimony, if any, pertinent to the d.ischarge, WDRs, and peTI11it. Oral testimony will be heard;however,Jor accuracy ofthe record, impOltant testimony should be in writing. .

Dates and venues may change. The Regional Water Board Web address ishttp://www.waterboards.ca.gov/sanfranciscobaywhere one .can. access the .current agenda forchanges in dates and locations..

D. 'Waste Discharge Requirements Petitions

Any aggrieved person may petition the State Water Resources Control Board to review the decisionof the Regional Water Board regarding the final WDRs. The petition must be submitted within30 days oftheRegional Water Board's action to the following address:

State Water Resources Control BoardOffice of Chief CounselP~O. Box 100, 10011 StreetSaCratl1ento, CA 95812-0100

E. Information and Copying

The ReportofWaste Discharge (permit application), related documents, tentative effluentlimitations and special provisions, COlllinents received, and other infoTI11ation are on file and may.beinspected at the address above at any time between 8:30 a.m. and 4:45 p.m., except from noon to1:00 p.m., Monday through Friday. Copying of documents may be arranged through the RegionalWater Board by calling 510-622-2300.

F. Register of Interested'Persons

Any person interested in being placed on(the mailing listforinfon1).ation regarding these WDRs andthIs NPDES pennit should contact the Regional Water Board, reference the Fairfield-Suisun SewerDistrict Wastewater Plant, and provide a name, address, and phone number.

G. Additional Information

Requests for additional infonnation or questions regarding this Order should be directed to. Adrienne Miller at 5W-622-24 I5 (e-mail [email protected]). .



ATTACHMENT H - PRETREATMENT REQUIREMENTS


Pretreatment Program Provisions

1. The Discharger shall implement all pretreatment requirements contained in 40 CFR 403, as 'amended. The Discharger shall be subject to enforcement actions, penalties, and fines as provided iniEeClean\Vater A.ct (33lJSC 135retseg.),uasaInel1decl.TheblsaJ.ai~geI" shal1impfemel'liandenforce its Approved Pretreatment Program or modified Pretreatment Program as directed by theBoard's Executive Officer or the USEPA. The USEPA and/or the State may initiate enforcementaction against anindustrial user for noncompliance 'with applicable standards and requirements asprovided in the Clean Water Act.

2. The Discharger shall enforce the requirements promulgated under Sections 307(b), 307(c), 307(d)and 402(b) of the Clean Water Act. The Discharger shall cause industrial users subject to federalCategorical Standards to achieve compliance no later than the date specified in those requirementsor, in the case of a new industrial user, upon commencement of the discharge.

3. The DischargeI shall perform the pretreatment functions as required in 40 CFR Part 403 andamendments or modifications thereto including, but not limited to:

a. Implement the necessary legal authorities. to fully implement the pretreatment regulations asprovided in 40 CFR 403.8(£)(1);

b. Implelilent the programmatic functions as provided in 40 CFR 403.8(£)(2);c. Publish an annual list of industrial users in significant noncompliance as provided per 40 CFR

403.8(£)(2)(vii);d. Provide for the requisite funding and persOlIDel to implement the pretreatment program as

provided in 40 CFR 403.8(£)(3); ande. Enforce the national pretreatment standards for prohibited discharges and categorical standards

as provided in 40 CFR 403.5 and 403.6, respectively.

4. The Discharger shall submit annually a report to USEPA Region 9, the State Board and the RegionalWater Bo'ard describing its pretreatment program activities over the previous twelve months. In theevent that the Discharger is not in compliance with any conditions or requirements of thePretreatment Program, the Discharger shall also include the reasons for noncompliance and a planand schedule for achieving compliance. The report shall contain, but is not limited to, theinformation specified in Appendix A entitled, "Requirements for Pretreatment Annual Reports,"which is made a part of this Order. The annual report is due on the last day of February each year.

5. The Discharger shall submit semiannual pretreatment reports to USEPA Region 9, the State Boardand the Board describing the status of its significant industrial users (SIUs). The report shallcontain, but not is limited to, the information specified in Appendix B entitled, "Requirements forSemialIDual Pretreatment Reports," which is made part of this Order. The semiannual reports aredue July 31 st (for the period January through June) and January 31st (for the period July throughDecember) of each year. The Executive Officer may exempt a Discharger from the semiannual

'reporting requirements on a case by case basis subject to State Board and USEPA's comment andapproval.

Attachment H - Pretreatment Requirements B-1'



6. The Discharger may combine the annual pretreatment report with the semiannual pretreatment report(for the July through December reporting period). The combined report shall contain all of theinfom1ation requested in Appendices A and B and will be due on January 31 st of each year.

The Discharger shall conduct the monitoring of its treatment plant's influent, effluent, and sludge asdescribed in Appendix C entitled, "Requirements for Influent, Effluent and Sludge Monitoring," whichis made part of this Order. The results of the samplingand analysis, along with a discussion of anytrends, shall be submitted in the semiannual reports. A tabulation of the data shall be included in theammal pretreatment repOli. The Executive Officer may require more or less frequent monitoring on acase by case basis.

Attachment H - Pretreatment Requirements B-2


ORDER NO, R2-2009-0039NPDES NO. CA0038024

APPENDIX A

REQUIREMENTS FOR PRETREATMENT ANNUAL REPORTS,

The Pretreatment Annual Report is due each year on the last day of February. [Ifthe alillual reportiscombined with the SeIl'liaIl.llUal report (roi the July through15E£elnberpei16dj il1esubl'l'littaldea.dlineisJanuary 31 st of each year.] The purpose of the Annual Report is 1) to describe the status of the PubliclyOwned Treatment Works (POTW) pretreatment program and 2) to report on the effectiveness of theprogram, as detennined by comparing the results of the preceding year's program implementation. Thereport shall contain at a minimum, but is not limited to, the following information:

1. Cover Sheet

The cover. sheet must contain the name(s) and National Pollutant Discharge Elimination DischargeSystem (NPDES) permit number(s) of those POTWs that are part of the Pretreatment Program.Additionally, the cover sheet must include: the name, address and telephone number of apretreatment contact person; the period covered in the report; a statement of truthfulness; and thedated signature of a principal executive officer, ranking elected official, or other duly authorizedemployee who is responsible for overall operation of the POTW (40 CFR403.12G)).

2. Introduction

The Introduction shall include any pertinent background information related to the Discharger, thePOTW and/or the industrial user base of the area. Also, this section shall include an update on thestatus ofany Pretreatment Compliance Inspection (PCI) tasks, Pretreatment Perfonnance Evaluationtasks, Pretreatment Compliance Audit (PCA) tasks, Cleanup and Abatement Order (CAO) tasks, orother pretreatment-related enforcement actions required by the Regional Water Board or theUSEPA. A more specific discussion shall be included in the section entitled, "Program Changes."

3. Definitions

This section shall contain §llist of key terms and their definitions that the Discharger uses to describeor characterize elements of its pretreatment program.

4. Discussion of Upset, Interference and Pass Through

This section shall include a discussion of Upset, Interference or Pass Through incidents, if any, at thePOTW(s) that the Discharger knows of or suspects were caused by industrial discharges. Eachincident shall be described, at a minimum, consisting of the following infonnation:

a. a description ofwhat occurred;b. a description of what was done to identify the source;c. tIle name and address of the IU responsible;d. the reason(s) why the incident occurred;e. a description of the corrective actions taken; andf.an examination 'of the local and federal discharge limits and requirements for the purposes of

determining whether any additional limits or changes to existing requirements may be necessaryto prevent other Upset, Interference or Pass TlIToughincidents.

'"

I

Attachment B - Pretreatment Requirements . B-3


5. Influent, Effluent and Sludge Monitoring Results


This section shall provide a summary of the analytical results from the "Influent, Effluent andSludge Monitoring" as specified in Appendix C The results should be repolied in a summarymatrix that lists monthly influent and effluent metal results for the reporting year.

A graphical representatioii-6f the ii1.f1uent and efflllel1frrietalmOl1.itoriilgda.ta .fOl: the pasffive yearsshall also be provided with a discussion of any trends.

6. Inspection and Sampling Program.

This section shall contain at a minimum, but is not limited to, the following infoDllation:

a. Inspections: the number of inspections performed for each type ofIU; the criteria fordetermining the frequency of inspections; the inspection format procedures;

b. Sampling Events: the number of sainpling events perfol1ned for each type ofIU; the criteria fordetemlining the frequency of sampling; the chain of custody procedures.

7. Enforcement Procedures

This section shall provide infonnation as to When the approved Enforcement Response Plan (ERP)had been fonnally adopted or last revised. In addition, the date the finalized ERP was submitted tothe Regional Water Boar.d shall also be given.

8. federal Categories

This section shall contain a list of all of the federal" categories that apply to the Discharger. Thespecific category shall be listed inclu4ing the subpart and 40 CFR section that applies. Themaximum arid average limits for the each category shall be provided. This list shall indicate thenumber of Categorical Industrial Users (CIUs) per category and the CIUs that are being regulated

.pursuant to the category. Theinfol1nation and data used to detehnine the limits for those CIUs forwhich a combined waste stream fOl1nula is applied shall also be provided.

9. Local Standards

This section shall include a table presenting the local limits.

10. Updated List of Regulated SIUs

This section shall contain a complete and updated list of the Discharger's Significant IndustrialUsers (SIUs), including their names, addresses, and a brief description of the individual SID's typeof business. The list shall include all deletions and additions keyed to the list as ~ubmitted in·theprevious annual repOli. All deletions shall be briefly explained.

11. Compliance Activities

a. Inspection and Sampling Summary: This section shall contain a summary of all theinspections and sampling activities conducted by the Discharger over the past year to gatherinfomlatiori and data regarding the SIUs. The summary shall include:

(1) the number of inspections and sampling events conducted for each SIU;

AttachmentH- Pretreatment Requirements H-4


ORDER NO. R2-2009-0039NPDES NO: CA0038024

(2) the quarters in which these activities were conducted; and(3) the compliance status of each SIU, delineated by quarter, and characterized using all

applicable descriptions as given below:(4) in consistent compliance;(5) in inconsistent compliance;(6) in si"gl1ifical1t tioncompliance;(7) on a compliance schedule to achieve compliance, (include the date final compliance is

required);(8) not in compliance and not on a compliance schedule;(9) compliance status unknown, and why not.

b. Enforcement Summary: This section shall contain a summary of the compliance andenforcement activities during the past year. The summary shall include the names of all the SIUsaffected by the following actions:(1) Wamingletters or notices of violations regarding SIUs' apparentnoncompliance with or

violation of any federal pretreatment categorical standards and/or requirements, or locallimits and/or requirements. For each 110tice, indicate whether it was for an infraction of afederal or local standard/limit or requirement.

(2) Administrative Orders regarding the SIUs' apparent noncompliance with or violation of anyfederal pretreatment categorical standards and/or requirements, or local limits and/orrequirements. For each notice, indicate whether it was for an infraction of a federal or localstandard/limit or requirement.

(3) Civil actions regarding the SIUs' apparent noncompliance with or violation of any federalpretreatment categorical standards and/or requirements, or local limits and/or requirements.For each notice, indicate whether it.was for an infraction of a federal or local standard/limitor requirement. .

(4) Criminal actions regarding the SIUs' apparent noncompliance with or violation ·of anyfederal pretreatment categorical standards and/or requirements, or local limits and/orrequirements. For each notice, indicate whether it was for an infraction of a federal or localstandard/limit or requirement.

. (5) Assessment of monetary penalties. Identify the amount ofpenalty in each case and reasonfor assessing the penalty. .

(6) Order to restrict/suspend discharge to the POTW.(7) Order to disconnect the discharge from entering the POTW.

12. Baseline Monitoring Report Update

This section shall provide a list of crus that have been added to the pretreatment program since the·last annual report. This list of new CIUs shall summarize the status of the respective Baseline·Monitofing Reports (BMR). The BMR must contain all of the information specified in 40 CFR403.l2(b). For each of the new CIUs, the summary shall indicate when the BMR was due; when theCIU was notified by the POTW of this requirement; when the CIU submitted the report; and/or whenthe report is due.

13. Pretreatment Program Changes

This section shall contain a description of any significant changes in the Pretreatment Programduring the past year including, but not limited to: legal authority, locallinlits, monitoring/ inspectionprogram and frequency, enforcement protocol, program's administrative structure, staffing level,

Attachment H - Pretreatment Requirements H-5 -

Fairficld-Suisun Scwcr DistrictWastcwatcr Trcatmcnt Plant


resource requirements and funding mechanism. If the manager of the pretreatment programchanges, a revised organizational chart shall be included. If any element(s) of the program is in theprocess of being modified, this intention shall also be indicated.

, 14) Pretreatment PJ~Qgram Budget

This section shall present the budget spent on the Pretreatment Program. The budget, either by thecalendar or fiscal year, shall show the amounts spent on personnel,equipment, chemical analysesand any other appropriate categories. A brief discussion of the source(s) of funding shall beprovided.

15) Public Participation Summary

This section shall include a copy of the public notice as required in 40 CFR 403. 8(f)(2)(vii). If anotice was not published, the reason shall be stated.

16) Sludge Storage and Disposal Practice

This section shall have a description of how the treated sludge is stored and ultill1ately disposed.The sludge storage area, if one is used, shall be described in detaiL Its location, a description of thecontainment features and the sludge handling procedures shall be included.

17) pes Data Entry Form

The annual report shall include the PCS Data Entry Fonn. This foml shall sununarize theenforcement actions taken against SIUs in the past year. This fonn shall include the followinginformation: the POTW name, NPDES Pennit number, period covered by the report, the number ofSIUs in significant noncompliance (SNC) that are on a pretreatment compliance schedule, thenumber of notices of violation and administrative orders issued against SIUs, the number of civil andcriminal judicial actions against SIDs, the number of SIUs that have been published as a result ofbeing in SNC, and the number of SIUs from which penalties have been collected.

18) Other Subjects

Other infomlation related to the Pretreatment Program that does not fit into one of the abovecategories should be included in this section.

Signed copies of the reports shall be submitted to the Regional Administrator at USEPA, the StateWater Resources Control Board and the Regional Water Board at the following addresse~:

Regional AdministratorUnited States Environmen'tal Protection AgencyRegion 9, Mail Code: WTR-7Clean Water Act Compliance OfficeWater Division75 Hawthome StreetSan Francisco, CA 94105

Attachment H - Pretreatment Requirements H-6

Fairfield·Suisun Sewer DistrictWastewater Treatment Plant

Pretreatment Program ManagerRegulatory UnitState Water Resources Control BoardDivision of Water Quality1001 I StreetSaciaii1ento~CA 95814

Pretreatment CoordinatorNPDES Permits DivisionSF Bay Regional Water Quality Control Board1515 Clay Street, Suite 1400Oakland, CA 94612

Attachment B - Pretreatment Requirements

ORDER NO. R2·2009-0039. NPDES NO. CA0038024

B-7

Fairfield-Suisun Sewer DistrictWastewater Trearment Plant


APPENDIXB:

REQUIREMENTS FOR SEMIANNUAL PRETREATMENT REPORTS

The semiannual pretreatment reports are due on July 31 st (for pretreatment program activities conductedfrom January througl1.Tune) allcl Jalluary 3pt (fol: pl:etreatlllelltactlviiies cOI'lcllideclfrolilJuly tIll-ougll .December) of each year, unless an exception has been granted by the Board's Executive Officer. Thesemiannual repolis shall contain, at a minimum, but is not limited to, the following information:

1. Influent, Effluent and Sludge Monitoring

The influent, effluent and sludge monitoring results shall be included in the report. The analyticallaboratory repOli shall also be iIwluded, with the QA/QC data validation provided upon request. Adescription of the sampling procedures and a discussion of the results shall be given. (Please seeAppendix C for specific detailed requirements.) The contributing source(s) of the parameters thatexceed NPDES limits shall be investigated and discussed. In addition, a brief discussion of thecontributing source(s) of all organic compounds identified shall be provided.

The Discharger has the option to submit all monitoring results via an electronic repoliing fomlatapproved by the Executive Officer. The procedures for submitting the data will be similar to theelectronic submittal of the NPDES self-monitoring reports as outlined in the December 17, 1999Regional Water Board letter, Official Implementation of Electronic Reporting System (ERS). TheDischarger shall contact the Regional Water Board's ERS Project Manager for specific details insubmitting the monitoring data.

If the monitoring results are submitted electronically, the analytical laboratory reports (along withthe QA/QC data validation) should be kept at the discharger's facility.

2. Industrial User Compliance Status

This section shall contain a list of all Significant Industrial Users (SIUs) that were not in consistentcompliance with all pretreatment standards/limits or requirements for the reporting period. Thecompliance status' for the previous reporting period shall also be included. Once the SIU hasdetermined to be out of compliance, the SIU shall be included in the report until consistentcompliance has been achieved. A brief description detailing the actions that the SIU undertook tocome back into compliance shall be provided.

For each SIU on the list, the following information shall be provided:

a. Indicate if the SIU is subject to federal categorical standards; if so, specify the category includingthe subpart that applies.

b. For SIUs subject to federal Categorical Standards, indicate if the violation is ofa categorical orlocal standard. .

c. Indicate the compliance status of the SIU for the two quarters of the reporting period.d. For violations/noncompliance occurring in the reporting period, provide (1) the date(s) of

violation(s); (2) the parameters and corresponding concentrations exceeding the limits and thedischarge limits for these parameters and (3) a brief summary ofthe noncompliant event(s) andthe steps that are being taken to achieve compliance.



3. POTW's Compliance with Pretreatment Program Requirements'

ORDER NO. R2-2009-0039, NPDES NO. CA0038024

This section shall contain a discussion of the Discharger's compliance status with the PretreatmentProgram Requirements as indicated in the latest Pretreatment Compliance Audit (PCA) Report,Pretreatment Compliance Inspection (PCI) Report or Pretreatment PerfoDnance Evaluation (PPE)Report.' It shaUcontainasummaryofthefoUowinginformation: '

a. Date of latest PCA, PCl or PPE and report.b. Date of the Discharger's response.c. List ofunresolved issues.d. Plan and schedule for resolving the remaining issues.

The reports shall be signed by a principal executive officer, ranking elected official, or other dulyauthorized employee who is responsible for the overall operation ofthe Publicly Owned Treatment 'Works (POTW) (40 CFR 403.l2(j)). Signed copies of the reports shall be submitted to the RegionalAdministrator at USEPA, the State Water Resources Control Board and the Regional Water Board at thefollowing addresses:

Regional AdministratorUni~ed States Environmental Protection AgencyRegion 9, Mail Code: WTR-7Clean Water Act Compliance OfficeWater Division75 Hawthorne StreetSan Francisco, CA 94105

Pretreatment Program ManagerRegulatory UnitState Water Resources Control BoardDivision of Water Quality1001 I StreetSacramento, CA 95814

Pretreatment CoordinatorNPDES Permits DivisionSF Bay Regional Water Quality Control Board1515 Clay Street, Suite 1400Oakland, CA 94612


Faitiield-SuiSUl1 Sewer DisttictWasiewater Treatment Plant,


APPENDIXC

REQUIREMENTS FOR INFLUENT, EFFLUENT AND SLUDGE MONITORING

The Discharger shall conduct sampling of its treatment plant's influent, effluent aqd sludge at theih:lquency as ShOWll iI1TablesE-4i:o E~6 oftheSelf~MollitoringPI'ogram(SMP).

The monitoring and reporting requirements of the POTW's Pretreatment Program are in addition tothose specified in Table 1 oftheSMP. Any subsequent modifications of the requirements specified inTable I shall be adhered to and shall not affect the requirements described in this Appendix unlesswritten notice from the Regional Water Board is received. When sampling periods coincide, one set oftest results, reported separately, may be used for those parameters that are required to be monitored byboth Table 1 and the Pretreatment Program. The Pretreatment Program monitoring reports shall be sentto the Pretreatment Program Coordinator.

1. Influent and Effluent Monitoring

The Discharger sh~ll monitor for the parameters using the required testmethods listed in Tables E-4,to E.:6 of the SMP. Any'test method substitutions must have received prior written Regional WaterBoard approval. Influent and Effluent sampling locations shall be the same as those sites specifiedin the SMP.

The influent and effluent sampled should be taken during the same 24-hour period. All samples'must be representative of daily operations. A grab sample shall be used for volatile organiccompounds, cyanide and phenol. In addition, any samples for oil and grease, polychlorinatedbiphenyls, dioxins/furans, and polynuclear aromatic hydrocarbons shall be grab samples. For allother pollutants, 24-hour composite samples must be obtained through flow-proportioned compositesampling. Sampling and analysis shall be perfomled in accordance with the techniques prescribed in'40 CFR Part 136 and amendments thereto. For effluent n).onitoring, the reporting limits for theindividual parameters shall be at or below the minimum levels (MLs) as stated in the Policy forImplementation of Toxics Standards for Inland Surface Waters, Enclosed Bays, and Estuaries ofCalifornia (2000) [also known as the State Implementation Policy (SIP)]; any revisions to the MLsshall be adhered to. If aparameter does not have a stated minimum level, then the Discharger shallconduct the analysis using the lowest commercially available and reasonably achievable detectionlevels.

The following standardized report format should be used for submittal of the influent and effluentmonitoring report. A similar structured JOTInat may be used but will be subject to Regional WaterBoard approval. The monitoring reports shall be submitted with the Semiammal Reports.

a. Sampling ProGedures - This section shall include a brief discussion of the sample locations,collection times, how the sample was collected· (i.e., direct collection using vials or bottles, orother types of collection using devices such as automatic samplers, buckets, or beakers), types ofcontainers used, storage procedures and holding times. Include description of prechlorinationand chlorination/dechlorination practices during the samplingperiods~

b. Method of Sampling Dechlorination - A brief description of the sample dechlorination methodprior to analysis shall be provided. .

Attachment H - Pretreatment Requirements H-IO



c. Sample C,ompositing - The manner in which samples are composited shall be described. If thecompositing procedure is different from the test method specifications, a reason for the variationshall be provided.

d. Data Validation - All quality assurance/quality control (QA/QC) methods to be used shall bediscussed and summarized. These methods include, but are not limited to, spike samples, splitsa.mples, blaiilcsc!'nd stalidatds.Wa.ysitl WhichtheQA/QC data will be lfsedtoqualifytheanalytical test results shall be identified. A certification statement shall be submitted with thisdiscussion stating that the laboratory QA/QC validation data has been reviewed and has met thelaboratory acceptance criteria. The QA/QC validation data shall be submitted to the RegionalWater Board upon request:

e. A tabulation of the test results shall be provided.f Discussion of Results - The report shall include a complete discussion of the test results. If any

pollut~nts are detected in sufficient concentration to .upset, interfere or pass through plantoperations, the type ofpollutant(s) and potential source(s) shall be noted, along with a plan ofaction to control, eliminate, and/or monitor the pollutant(s). Any apparent generation and/ordestruction of pollutants attributable to chlorination/dechlorination sampling and analysispractices shall be noted.

2. Sludge Monitoring

Sludge should be sampled in the same 24-hour period during which the influent and effluent aresampled except as noted in (C) below. The same parameters required for influent and effluentanalysis shall be included in the sludge analysis. The sludge analyzed shall be a composite sampleof the sludge for final disposal consisting of:

a. Sludge lagoons - 20 grab samples collected at representative equidistant intervals (grid pattern)and composited as a single grab, or .

b. Dried stockpile - 20 grab samples collected at various representative locations and depths andcomposited as a single grab, or .

c. Dewatered sludge- daily composite of 4 representative grab samples each day for 5 days taken atequal intervals during the daily operating shift taken from a) the dewatering units or b) from eachtruckload, and shall be combined into a single 5-day composite.

The USEPA manual, POTW Sludge Sampling and Analysis Guidance Document, August 1989,containing detailed sampling protocols specific to sludge is recommended as a guidance forsampling procedures. The USEPA manual Analytical Methods of the National Sewage SludgeSurvey, September 1990, containing detailed analytical protocols specific to sludge, is recommendedas a guidance for analytical methods.

Indetermining if the sludge is a hazardous waste, the Dischargers shan adhere to Article 2, "Criteriafor Identifying the Characteristics of Hazardous Waste," and Article 3, "Characteristics ofHazardous Waste," of Title 22, California Code of Regulations, Sections 66261.10 to 66261.24 andall amendments thereto.

Sludge monitoring reports shall be submitted with the appropriate Semiannual Report. Thefollowing standardized report format should be used for submittal of the report. A similarlystructured form may be used but will be subject to Regional Water Board approval.

Attachment B - Pretreatment Requirements B-11



a.' Sampling procedures - Include sample locations, collection procedures, types of containers used,storage/refrigeration methods, compositing techniques and holding times. Enclose a map ofsample locations if sludge lagoons or stockpiled sludge is sampled.

b. Data Validation - All quality assurance/quality control (QA/QC) methods to be used shall be4iscussed and summarized. These methods include, but are not limited to, spike samples, splitsamples,blanks"'arrd·standards;-cWaysin whichtheQA/QedatawiU-beusedtoqualifythe .analytical test results shall be identified. A certification statement shall be submitted with this .discussion stating that the laboratory QA/QC validation data has been reviewed and has met thelaboratolY acceptance criteria. The QA/QC validation data shall be submitted to the RegionalWater Board upon request. .

c.Test Results - Tabulate the test results and include the percent solids.d.. Discussion of Results - The report shall include a complete discussion oftest results. If the

detected pollutant(s) is reasonably deemed to have an adverse effect on sludge disposal, a plan ofaction to control, eliminate, and/or monitor the pollutant(s) and the knOWl} or potential source(s)shall be included. Any apparent generation and/or destruction of pollutants attributable tochlorinationl dechlorination sampling and analysis practices shall be noted.

The Discharger shall also provide any influent, effluent or sludge monitoring data for nonprioritypollutants that the pemlittee believes may be causing or contributing to Interference, Pass Throughor adversely impacting sludge quality. .


d. waterquality-basedeffluent limitations (wqbels) · ntr) states that the salinity characteristics...

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